Troy Martin v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of Indiana denied Troy Martin’s motion to reconsider dismissal with prejudice of his action seeking review of the Commissioner of Social Security’s denial of disability benefits. The court held that counsel’s calendaring error did not establish excusable neglect or an extraordinary circumstance warranting relief from judgment or extension of the statutory filing deadline under 42 U.S.C. § 405(g).

Holdings

1. Martin's complaint was barred by the sixty-day limitation period governing judicial review of the Commissioner's final decision.
2. Counsel's calendaring error and alleged postal delay did not establish excusable neglect or justify extending the deadline for filing Martin's complaint.
3. Martin was not entitled to relief from the judgment under Rule 60(b)(1) or Rule 60(b)(6).
4. Macure v. Lynn did not require reconsideration because the dismissal rested on the untimeliness of the complaint, not solely on Martin's failure to respond to the motion to dismiss.

Questions Presented

1. Whether Martin's complaint was barred by the sixty-day statute of limitations for judicial review under 42 U.S.C. § 405(g).
2. Whether counsel's calendaring error and alleged postal delay constituted excusable neglect warranting an extension under Federal Rule of Civil Procedure 6(b)(1)(B).
3. Whether those circumstances constituted an extraordinary circumstance warranting relief from the final judgment under Federal Rule of Civil Procedure 60(b).
4. Whether Macure v. Lynn required reconsideration because Martin failed to respond timely to the Commissioner's motion to dismiss.

Disposition

other