Lee v. Commissioner of SSA

CourtDistrict Court, D. Massachusetts
DecidedNovember 20, 2024
Docket1:24-cv-11404
StatusUnknown

This text of Lee v. Commissioner of SSA (Lee v. Commissioner of SSA) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lee v. Commissioner of SSA, (D. Mass. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

_______________________________________ ) H.L. and D.J., ) ) Plaintiffs, ) ) v. ) Civil Action No. ) 24-11404-FDS MARTIN O’MALLEY, Commissioner ) of the Social Security Administration, ) ) Defendant. ) _______________________________________)

MEMORANDUM AND ORDER ON DEFENDANT’S MOTION TO DISMISS SAYLOR, C.J. This action is a direct challenge to a Social Security benefits determination. Because the Court lacks subject-matter jurisdiction over this claim, the complaint will be dismissed. I. Background The facts are as alleged in the plaintiffs’ first amended complaint.1 Additional facts asserted in defendant’s briefing are included for clarity and completeness, but only to the extent they are uncontested. A. Factual Background D.J. lives with her son, H.L., in Beverly, Massachusetts. (Am. Compl. at 8). Before December 2023, D.J. received $609 in federal supplemental security income (SSI) and $104 in

1 Plaintiffs subsequently filed a second amended complaint without seeking the government’s consent or leave of the Court, as required. See Fed. R. Civ. P. 15(a)(2). In light of plaintiffs’ pro se status, the Court will liberally construe the second amended complaint as a motion for leave to file an amended complaint. That motion is denied. For the reasons described more fully below, amendment would be futile. See Foman v. Davis, 371 U.S. 178, 182 (1962) (describing circumstances where leave to amend may be denied, including “futility of amendment”). state supplementary payments (SSP) each month. (Id. at 1). H.L. does not receive public assistance of his own, but he receives representative payments on D.J.’s behalf. (Id. at 6; ECF 13 at 2). In December 2023, D.J.’s monthly state-level supplemental income was reduced to $39

from $104. (Am. Compl. at 1) In February 2024, the Social Security Administration issued D.J. a notice of a change in payment increasing her monthly SSI income from $609 to $630. (Am. Compl. Ex. B at 1). The notice also indicated that D.J. was entitled to fewer benefits than she otherwise would be because she receives food and shelter valued at between $300 and $335 each month. (Id.). The complaint asserts, however, that D.J. receives no income other than her supplemental security income payments each month. (Am. Compl. at 5). Along with the notice, D.J. received a letter describing how to appeal the determination. (ECF 15 Ex. A at 2-4). The complaint does not allege that plaintiffs filed an appeal. (Am. Compl.). This action followed.

B. Procedural Background Plaintiffs filed suit against the Salem Social Security Office in Salem District Court on April 29, 2024.2 Defendants timely removed the case on May 28, 2024. (ECF 1). Plaintiffs amended their complaint on July 3, 2024. On September 5, 2024, Martin O’Malley, Commissioner of the Social Security Administration, filed a motion to dismiss the complaint for lack of subject-matter jurisdiction under Fed. R. Civ. P. 12(b)(1) and for failure to state a claim upon which relief can be granted

2 It appears that D.J. is being represented in this action by H.L., her son. Although they are both named as plaintiffs proceeding pro se, only he has signed the pleadings. (Am. Compl. at 8). To the extent that he is representing his mother’s interests, he has violated Local Rule 83.5.5(b), which provides that a pro se litigant may not “represent any other party.” Id. under Fed. R. Civ. P. 12(b)(6). Plaintiffs did not oppose the motion, but instead filed a second amended complaint substituting the Commissioner for the Salem Social Security Office as defendant. The Commissioner opposed the amendment and, in the alternative, moved to dismiss the second amended complaint for the same reasons outlined in his motion to dismiss the first

amended complaint. II. Standard of Review On a motion to dismiss for lack of subject-matter jurisdiction pursuant to Rule 12(b)(1), “the party invoking the jurisdiction of a federal court carries the burden of proving its existence.” Johansen v. United States, 506 F.3d 65, 68 (1st Cir. 2007) (quoting Murphy v. United States, 45 F.3d 520, 522 (1st Cir. 1995)). If the party seeking to invoke federal jurisdiction “fails to demonstrate a basis for jurisdiction,” the motion to dismiss must be granted. Id. When ruling on a motion to dismiss under Rule 12(b)(1), the court “must credit the plaintiff’s well-[pleaded] factual allegations and draw all reasonable inferences in the plaintiff’s favor.” Merlonghi v. United States, 620 F.3d 50, 54 (1st Cir. 2010). To survive a motion to dismiss under Rule 12(b)(6), the complaint must state a claim that

is plausible on its face. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). In other words, the “[f]actual allegations must be enough to raise a right to relief above the speculative level, . . . on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Id. at 555 (citations omitted). “The plausibility standard is not akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 556). When determining whether a complaint satisfies that standard, a court must assume the truth of all well- pleaded facts and give the plaintiff the benefit of all reasonable inferences. See Ruiz v. Bally Total Fitness Holding Corp., 496 F.3d 1, 5 (1st Cir. 2007) (citing Rogan v. Menino, 175 F.3d 75, 77 (1st Cir. 1999)). Dismissal is appropriate if the complaint fails to set forth “factual allegations, either direct or inferential, respecting each material element necessary to sustain recovery under some actionable legal theory.” Gagliardi v. Sullivan, 513 F.3d 301, 305 (1st Cir. 2008) (quoting Centro Médico del Turabo, Inc. v. Feliciano de Melecio, 406 F.3d 1, 6 (1st Cir.

2005)). III. Analysis The Commissioner contends that this case must be dismissed for lack of subject-matter jurisdiction because it was originally filed in state court, which has no jurisdiction over challenges to Social Security benefits determinations. See 42 U.S.C. § 405(g) (challenges to final actions of the SSA “shall be brought in the district court of the United States for the judicial district in which the plaintiff resides”). Under the doctrine of derivative jurisdiction, “a federal district court does not have removal jurisdiction over a claim that the state court lacked subject matter jurisdiction to decide in the first place.” Patriot Cinemas, Inc. v. General Cinemas Corp., 834 F.2d 208, 210 (1st Cir.

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Related

Minnesota v. United States
305 U.S. 382 (Supreme Court, 1939)
Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Merlonghi v. United States
620 F.3d 50 (First Circuit, 2010)
Murphy v. United States
45 F.3d 520 (First Circuit, 1995)
Rogan v. Menino
175 F.3d 75 (First Circuit, 1999)
Ruiz v. Bally Total Fitness Holding Corp.
496 F.3d 1 (First Circuit, 2007)
Johansen v. United States
506 F.3d 65 (First Circuit, 2007)
Gagliardi v. Sullivan
513 F.3d 301 (First Circuit, 2008)
Patriot Cinemas, Inc. v. General Cinema Corp.
834 F.2d 208 (First Circuit, 1987)
Randal Ricci v. Darrin Salzman
976 F.3d 768 (Seventh Circuit, 2020)

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Lee v. Commissioner of SSA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lee-v-commissioner-of-ssa-mad-2024.