Seanise N. Webb v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of North Carolina overruled Seanise N. Webb’s objections to a magistrate judge’s Memorandum and Recommendation in a Social Security disability case. The court declined to consider medical documents submitted for the first time in the objection and denied the motion to supplement. It adopted the recommendation, affirmed the Commissioner’s final decision, granted the Commissioner’s request for relief, and closed the case.

Holdings

1. Objections must be specific and particularized and direct the district court to a specific error; general and conclusory objections do not trigger de novo review, and unobjected portions are reviewed for clear error.
2. In reviewing an ALJ's factual findings, the district court may not consider evidence that was not presented to the ALJ.
3. The Commissioner's final disability determination must be upheld because the ALJ applied the correct legal standards and substantial evidence supported the ALJ's findings.
4. The ALJ properly evaluated Plaintiff's subjective symptom statements by determining that her impairments could produce the alleged symptoms and then assessing the intensity, persistence, and limiting effects of those symptoms against the entire record.

Questions Presented

1. Whether Plaintiff's objections to the magistrate judge's Memorandum and Recommendation were sufficiently specific and particularized to require de novo review.
2. Whether the district court could consider medical documents submitted with Plaintiff's objections or motion to supplement that were not presented to the ALJ.
3. Whether the ALJ applied the correct legal standards and supported the Social Security disability determination with substantial evidence.
4. Whether the magistrate judge accurately described the ALJ's factual and procedural findings and properly recommended affirmance.

Disposition

affirmed