Steve Urias v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California denied the Commissioner of Social Security’s motion to dismiss for lack of subject matter jurisdiction. The court held that the complaint was timely because electronic filing occurred before midnight on the filing deadline, despite the docket reflecting the following day, and reset the deadline for filing the administrative record and an answer or cross-motion to July 14, 2025.

Holdings

1. A challenge to compliance with the conditions of the government's consent to suit under 42 U.S.C. § 405(g) is properly understood as a motion to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1), rather than solely as a Rule 12(b)(6) failure-to-state-a-claim motion.
2. The complaint was timely because credible CM/ECF evidence showed that plaintiff filed it before midnight on October 30, 2024, the filing deadline; the system's recording of October 31 did not defeat timeliness.

Questions Presented

1. Whether the Commissioner's challenge to the timeliness of the Social Security complaint was properly treated as a motion to dismiss for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1).
2. Whether the complaint was timely filed when plaintiff electronically submitted it before midnight on the deadline, although the court's electronic filing system docketed it on the following day.
3. Whether the court should reset the remaining case deadlines after denying the motion to dismiss.