DANIEL H. v. FRANK BISIGNANO, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Iowa reviewed a magistrate judge’s report and recommendation in a Social Security disability benefits action. Finding no clear error and substantial evidence supporting the Commissioner’s decision, the court adopted the recommendation, affirmed the denial of benefits, and entered judgment for the Commissioner.

Holdings

1. When neither party objects to a magistrate judge's Report and Recommendation, the district court may review the recommendation for clear error; the court did so here and found no clear error.
2. The Commissioner's determination that Daniel H. was not disabled is affirmed because it was supported by substantial evidence and the magistrate judge's recommendation disclosed no clear error.

Questions Presented

1. Whether the magistrate judge's Report and Recommendation contained clear error when it concluded that the administrative law judge adequately considered the claimant's need for a hand-held assistive device, medical history, treatment, and subjective allegations.
2. Whether the Commissioner's determination that Daniel H. was not disabled was supported by substantial evidence on the record as a whole.

Disposition

affirmed