Kristen M. H. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of New York adopted a magistrate judge’s Report-Recommendation in an action challenging the denial of Social Security disability insurance benefits and supplemental security income. The court granted the plaintiff’s cross-motion, denied the Commissioner’s cross-motion, reversed the Commissioner’s decision, and remanded for further proceedings.

Holdings

1. When no party properly objects to a magistrate judge's Report-Recommendation, the district court reviews the recommendation for clear error rather than de novo review.
2. The Report-Recommendation was adopted in all respects; plaintiff's cross-motion was granted, the Commissioner's cross-motion was denied, and the Commissioner's decision was reversed and remanded for further proceedings.
3. The apparent misstatement was harmless and did not warrant altering the recommendation because the intended meaning was clear from context and no party objected.

Questions Presented

1. What standard of review governs a magistrate judge's Report-Recommendation when the parties file no objections?
2. Whether the magistrate judge's recommendation to reverse and remand the Commissioner's decision should be adopted after clear-error review.
3. Whether an apparent misstatement in the Report-Recommendation concerning the vocational expert's treatment of plaintiff's light-related limitations required correction or affected the disposition.

Disposition

reversed_and_remanded