Laurie A. Hubbard v. Commissioner of Social Security

Summary

The United States District Court for the Western District of Michigan adopted the magistrate judge’s report and recommendation and affirmed the Commissioner of Social Security’s denial of Laurie A. Hubbard’s application for disability insurance benefits before her insured status expired. The court concluded that Hubbard’s objections were general disagreements and did not identify a specific factual or legal error warranting de novo review.

Holdings

1. Only specific objections to a magistrate judge's proposed findings and recommendations are entitled to de novo review; general disagreements with the report, the ALJ, or the process are insufficient.
2. The district court could not consider medical conditions that Hubbard had not presented to the Social Security Administration, the ALJ, or the magistrate judge.
3. The Commissioner's decision denying disability insurance benefits for the period before October 23, 2023, was affirmed.

Questions Presented

1. Whether Hubbard's objections to the magistrate judge's report and recommendation were sufficiently specific to require de novo review.
2. Whether the magistrate judge correctly recommended affirming the Commissioner's determination that Hubbard was not disabled before the expiration of her insured status.
3. Whether the district court could consider medical conditions raised for the first time in objections and not presented to the Social Security Administration, the ALJ, or the magistrate judge.

Disposition

affirmed