Sharon H. v. Frank Bisignano

Summary

The United States District Court for the Central District of Illinois adopted a magistrate judge’s Report and Recommendation and affirmed the Commissioner of Social Security’s denial of Sharon H.’s application for disability insurance benefits. The court found no clear error in the recommendation and denied the plaintiff’s motions, including submissions presenting evidence outside the administrative record.

Holdings

1. On review under 42 U.S.C. § 405(g), the court determines whether the Commissioner's decision is supported by substantial evidence and rests on the proper legal standard; it does not independently decide whether the claimant is disabled or reweigh the evidence.
2. When no party properly objects to a magistrate judge's recommended disposition, the district court reviews the unobjected portions for clear error.
3. In reviewing a Social Security disability determination under § 405(g), the district court generally may not consider evidence that was not before the Social Security Administration.
4. Plaintiff's submissions, insofar as construed as motions, were procedurally improper and were properly denied.

Questions Presented

1. Whether the magistrate judge clearly erred in recommending affirmance of the Commissioner's denial of disability insurance benefits.
2. Whether the district court could consider materials and evidence that were not presented to the Social Security Administration.
3. Whether plaintiff's submissions constituted procedurally proper motions warranting relief from the administrative decision.

Disposition

affirmed