Audrey S. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey denied a pro se plaintiff’s appeal from the Social Security Administration’s denial of disability insurance benefits retroactive to her alleged disability-onset date. The court held that 42 U.S.C. § 423(b) constitutionally limits retroactive disability insurance benefits to the 12 months preceding the application date and found substantial evidence supporting the determination that plaintiff’s November 4, 2019 application was her first application.

Holdings

1. Section 423(b) imposes a statutory one-year limitation on the payment of retroactive disability insurance benefits, so Plaintiff could not receive benefits for any period before November 2018 based on her November 4, 2019 application.
2. The twelve-month limitation in 42 U.S.C. § 423(b) is constitutional and does not violate due process or equal protection.
3. Substantial evidence supported the ALJ's finding that Plaintiff filed no disability insurance benefits application before November 4, 2019.

Questions Presented

1. Whether 42 U.S.C. § 423(b) permits disability insurance benefits to be paid for more than twelve months before the filing of an application.
2. Whether the statutory twelve-month limitation on retroactive disability insurance benefits violates due process or equal protection.
3. Whether substantial evidence supported the ALJ's finding that Plaintiff had filed no disability insurance benefits application before November 4, 2019.

Disposition

other