Cynthia M. Yoder v. Frank Bisignano, Commissioner of Social Security Administration

Summary

This Memorandum and Recommendation addresses Cynthia M. Yoder’s application to proceed in forma pauperis and the required frivolity review of her action against the Commissioner of Social Security. The magistrate judge recommends allowing in forma pauperis status, construing the complaint as an action for judicial review under 42 U.S.C. § 405(g), and dismissing other claims as frivolous or for failure to state a claim. The document is dated February 17, 2026.

Holdings

1. Plaintiff meets the poverty-based standard for proceeding in forma pauperis, and the application should be allowed.
2. Liberally construed, Plaintiff's complaint states a claim for judicial review of the Commissioner's final administrative decision under 42 U.S.C. § 405(g), and that claim survives frivolity review.
3. Claims arising under the Social Security Act, including Plaintiff's allegations of judicial misconduct, discrimination, negligence, and civil-rights violations, must be pursued through the exclusive remedy provided by 42 U.S.C. § 405(g) and should otherwise be dismissed as frivolous or for failure to state a claim.

Questions Presented

1. Whether Plaintiff should be permitted to proceed in forma pauperis under 28 U.S.C. § 1915(a)(1).
2. Whether Plaintiff's complaint states a nonfrivolous claim for judicial review of the Commissioner's final decision under 42 U.S.C. § 405(g).
3. Whether Plaintiff's additional claims arising from the denial or processing of Social Security benefits are barred by 42 U.S.C. § 405(h) or otherwise subject to dismissal as frivolous or for failure to state a claim.

Disposition

other