Pablo J. H. v. Commissioner of Social Security

District Court, S.D. New York·Decided March 19, 2026·No. 7:25-cv-03994·Unknown

Opinion

DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #:

PABLO J. H., Plaintiff, OPINION & ORDER -against- . : 25 Civ. 03994 (NSR)\(JCM) COMMISSIONER OF SOCIAL SECURITY, Defendant.

NELSON S. ROMAN, United States District Judge Plaintiff Pablo J. H. (‘Plaintiff’), appearing pro se, commenced this action pursuant to 42 U.S.C. § 405(g), challenging the decision of the Commissioner of Social Security (the “Commissioner”), which denied his application for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”) under the Social Security Act (the “Act”). (Docket No. 1.) On May 29, 2025, the Court referred this case to Magistrate Judge Judith C. McCarthy (“MJ McCarthy”) pursuant to 28 U.S.C. § 636(b) and Federal Rule of Civil Procedure 72(b) to issue a Report and Recommendation (“R & R”). On February 24, 2026, MJ McCarthy issued an R & R recommending that the Commissioner’s motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), or in the alternative for summary judgment pursuant to Rule 56, be granted on the ground that Plaintiff's claims are time-barred under Section 205(g) of the Act, 42 U.S.C. § 405(g). (ECF No. 18.) The matter is now before the Court. For the reasons set forth below, the Court adopts the R & R in its entirety. BACKGROUND

Plaintiff commenced the instant action on May 8, 2025. (ECF No. 1.) On July 24, 2025, the Commissioner filed a motion to dismiss or, in the alternative, for summary judgment. (ECF No. 8.)

with accompanying exhibits (ECF No. 10), and a Statement of Material Facts pursuant to Local Rule 56.1 (ECF No. 11). The Commissioner also filed the requisite notices to pro se litigants under Local

Civil Rules 12.1 and 56.2. (ECF Nos. 12–13.) Plaintiff did not file an opposition. MJ McCarthy issued her R & R on February 24, 2026. STANDARD OF REVIEW “To accept the report and recommendation of a magistrate, to which no timely objection has been made, a district court need only satisfy that there is no clear error on the face of the record.” Wilds v. United Parcel Serv., Inc., 262 F. Supp. 2d 163, 169 (S.D.N.Y. 2003) (quoting Nelson v. Smith, 618 F. Supp. 1186, 1189 (S.D.N.Y. 1985)); accord Caidor v. Onondaga County, 517 F.3d 601, 604 (2d Cir. 2008) (“[F]ailure to object timely to a magistrate’s report operates as a waiver of any further judicial review of the magistrate’s decision.”) (quoting Small v. Sec. of HHS, 892 F. 2d 15, 16 (2d Cir. 1989)); see also Fed. R. Civ. P. 72 advisory committee note (1983 amendment, Subdivision

(b)) (“When no timely objection is filed, the court need only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.”). When reviewing an appeal from a denial of SSI, the Court’s review is “limited to determining whether the SSA’s conclusions were supported by substantial evidence in the record and were based on a correct legal standard.” Selian v. Astrue, 708 F.3d 409, 417 (2d Cir. 2013) (quoting Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012)); see also 42 U.S.C. § 405(g). The Court does not substitute its judgment for the agency’s, “or determine de novo whether [the claimant] is disabled.” Cage v. Comm’r of Soc. Sec., 692 F.3d 118, 122 (2d Cir. 2012) (alteration in original) (quoting Schaal v. Apfel, 134 F.3d 496, 501 (2d Cir. 1998)). However, where the proper legal standards have not been

applied and “might have affected the disposition of the case, [the] court cannot fulfill its statutory and constitutional duty to review the decision of the administrative agency by simply deferring to the factual findings of the ALJ.” Pollard v. Halter, 377 F.3d 183, 189 (2d Cir. 2004) (quoting Townley is grounds for reversal.” Id. “Where there are gaps in the administrative record or the ALJ has applied an improper legal standard”, remand to the Commissioner “for further development of the evidence”

is appropriate. Rosa v. Callahan, 168 F.3d 82, 82-83 (2d Cir. 1999) (quoting Pratts v. Chater, 94 F. 3d 34, 39 (2d Cir. 1996)). DISCUSSION Neither Plaintiff nor the Commissioner timely objected to the R & R. Thus, the Court reviews the R & R for clear error. Upon a thorough review of the record and MJ McCarthy’s well- reasoned R & R, the Court finds that the conclusions reached are grounded in fact and law. Thus, the Court finds no clear error. As more detailed in the R & R, when a court converts a motion to dismiss into a motion for summary judgment it must give “sufficient notice to an opposing party and an opportunity for that party to respond.” Hernández v. Coffey, 582 F.3d 303, 307 (2d Cir. 2009) (quoting Groden v. Random

House, Inc., 61 F.3d 1045, 1052 (2d Cir. 1995)). When the opposing party is pro se, clear unambiguous notice of the meaning and consequences of conversion to summary judgment must be provided. Id. at 307-08 citing Beacon Enters., Inc. v. Menzies, 715 F.2d 757, 767 (2d Cir.1983). A review of the docket reveals the Commissioner provided and Plaintiff received formal and proper notice of the conversion of the motion pursuant to Local Civil Rule 12.1 (ECF No. 12.) The Commissioner moved for summary judgment on the basis that Plaintiff’s complaint was time-barred under Section 205(g) of the Act, 42 U.S.C. § 405(g). Section 205(g) of the Act states, in relevant part: “Any individual, after any final decision of the Commissioner of Social Security made after a hearing to which he was a party, irrespective of the amount in controversy, may obtain a review of such decision by a civil action commenced within sixty days after the mailing to him of notice of such decision or within such further time as the Commissioner of Social Security may allow.” The Act requires that a plaintiff challenging a final decision of the Commissioner to file a civil action within sixty (60) days of the plaintiff's receipt of the agency’s Appeals Council decision. 42 U.S.C. § 405(g). The “60-day requirement is not jurisdictional but rather constitutes a period of limitations.” Cole-Hill ex rel. T.W. v.

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