Eric Lee Steiert v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the Northern District of Oklahoma overruled Eric Lee Steiert’s objections to a magistrate judge’s Report and Recommendation and affirmed the Commissioner of Social Security’s denial of disability benefits. The court held that all but one objection was waived for failure to specifically identify errors in the Report and Recommendation. After de novo review of the remaining objection and clear-error review of the others, the court concluded that the ALJ’s evaluation of medical opinion evidence and subjective symptoms was supported by substantial evidence.

Holdings

1. Objections must identify particular factual or legal errors in the magistrate judge's recommendation; objections directed only to the underlying ALJ decision, or merely expressing disagreement with the recommendation, do not preserve the issue for de novo review. Steiert waived all but one objection.
2. The ALJ's determination that Mackey's June 28, 2023 medical opinion was inconsistent and unpersuasive was supported by substantial evidence.
3. The district court may review waived objections to a magistrate judge's report for clear error and found no clear error in the Report's treatment of the remaining issues.

Questions Presented

1. Whether Steiert's objections to the magistrate judge's Report and Recommendation were sufficiently specific to preserve them for de novo review.
2. Whether the ALJ's finding that Mackey's medical opinion was unpersuasive was supported by substantial evidence and adequately addressed the opinion's supportability and consistency.
3. Whether the ALJ properly analyzed Steiert's interaction and concentration limitations.
4. Whether the ALJ's subjective-symptom analysis was improper.

Disposition

affirmed