Ray v. Commissioner of Social Security

CourtDistrict Court, W.D. Virginia
DecidedMarch 18, 2025
Docket4:23-cv-00032
StatusUnknown

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

Bluebook
Ray v. Commissioner of Social Security, (W.D. Va. 2025).

Opinion

CLERKS OFFICE U.S. DIST. C IN THE UNITED STATES DISTRICT COURT AT □□ VA FOR THE WESTERN DISTRICT OF VIRGINIA ROANOKE DIVISION MAR 18 2025 LAURA A. AUSTIN, CLERK SABRINA R., o/b/o S.P., ) Bye 7) MEDONAD A MINOR CHILD, ) □ DERUTY CLERK Plaintiff ) Civil Action No. 4:23-CV-32 ) v. ) ) LELAND DUDEK, Acting ) Commissioner of Social Security,} ) By: Michael F. Urbanski ) Senior United States District Judge Defendant ) ORDER This social security disability appeal was filed by Plaintiff Sabrina R. (Sabrina), on behalf of her minor granddaughter, S.P. The appeal was referred to the Honorable Joel C. Hoppe, United States Magistrate Judge, pursuant to 28 U.S.C. § 636(b)(1)(B), for proposed findings of fact and a recommended disposition. The magistrate judge filed a report and recommendation (R&R) on January 31, 2025, recommending that the court affirm the Commissioner’s final decision and dismiss the case from the coutt’s active docket. ECF No. 21. Sabrina has filed objections to the R&R, ECF No. 22, and the Commissioner has replied, ECF No. 23. As discussed below, the court ADOPTS the R&R and AFFIRMS the determination by the Commissioner that S.P.’s prior disability ended on December 9, 2015, and that she had not become disabled again as of September 27, 2023.

1 Leland Dudek was named Acting Commissioner of the Social Security Administration in February 2025, Under Rule 25(d) of the Federal Rules of Civil Procedure, he is automatically substituted as the defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).

I. Legal Standards A. Objections to Magistrate Judge’s Report and Recommendation The objection requirement set forth in Rule 72(b) of the Federal Rules of Civil Procedure? is designed to “train[ ] the attention of both the district court and the court of appeals upon only those issues that remain in dispute after the magistrate judge has made findings and recommendations.” United States v. Midgette, 478 F.3d 616, 621 (4th Cir. 2007) (citing Thomas v. Arn, 474 U.S. 140, 147-48 (1985)). An objecting party must do so “with sufficient specificity so as teasonably to. alert the district court of the true ground for the objection.” Id. at 622. The district court must determine de novo any portion of the magistrate judge’s report and recommendation to which a proper objection has been made. “The district coutt may accept, reject, or modify the recommended disposition; receive further evidence; or return the matter to the magistrate jydge with instructions.” Fed. R. Civ. P. 72(b)(3); 28 U.S.C. § 636(6)(1). If, however, a party “‘makes general or conclusory objections that do not direct the court to a specific error in the magistrate judge’s proposed findings and recommendations,” de novo review is not required. Diprospero v. Colvin, No. 5:13-cv-00088-FDW-DSC, 2014 WL. 1669806, at *1 QW.D.N.C. Apr. 28, 2014) (quoting Howard Yellow Cabs, Inc. v. United States, 987 F. Supp. 469, 474 (W.D.N.C. 1997) and Orpiano v. Johnson, 687 F.2d 44, 47 (4th Cir. 1982)). “The district court is required to review de novo only those portions of the report to which specific objections have been made.” Roach y. Gates, 417 F. App’x 313, 314 4th

specific written objections to the proposed findings and recommendations.” Fed. R. Civ. P. 72(b).

Cir. 2011) (per curiam). See also Midgette, 478 F.3d at 621 (“Section 636(b)(1) does not countenance a form of generalized objection to cover all issues addressed by the magistrate judge; it contemplates that a party’s objection to a magistrate judge’s report be specific and particularized, as the statute directs the district court to review only ‘those portions of the report or specified proposed findings or recommendations to which objection is made.””) Such general objections “have the same effect as a failure to object, or as a waivet of such objection.” Moon v. BWX Technologies, 742 F. Supp. 2d 827, 829 (W.D. Va. 2010), aff'd, 498 F. App’x 268 (4th Cir. 2012). See also Arn, 474 U.S. at 154 (“[T]he statute does not require the judge to review an issue de noyo if no objections are filed. . ..””) Nevertheless, as the court clarified in Elijah v. Dunbar, 66 F.4th 454, 460 (4th Cir. 2023), “objections need not be novel to be sufficiently specific.” In Martin v. Duffy, 858 F.3d 239, 245-46 (4th Cir. 2017), this Court exemplified the specificity analysis by looking solely to whether the grounds for objection were clear. There, an objection □ which merely “restated all of [the] claims” was sufficiently specific because it “alerted the district court that [the litigant] believed the magistrate judge erred in recommending dismissal of those claims.” Id. at 246. If the grounds for objection are clear, district court judges must consider them de novo, or else run afoul of both § 636(b)(1) and Article ITZ. If a litigant could not restate his argument to the district judge, in addition to “needlessly curtailing litigants’ access to an Article III judge, such a requirement could leave litigants with no available arguments, as district court judges are not required to consider new arguments posed in objections to the magistrate’s recommendation.” Id. at n.4. In the absence of a specific, proper, and timely filed objection, a court reviews an R&R only for “clear error” and need not give any explanation for adopting the R&R. Carr v.

Comm’r of Soc. Sec., No. 3:20-cv-00425-FDW-DSC, 2022 WL 987336, at *2 (W.D.N.C. Mar. 31, 2022) (citing Diamond v. Colonial Life & Accident Ins. Co., 416 F.3d 310, 315 (4th Cir. 2005) and Camby v. Davis, 718 F.2d 198, 200 (4th Cir. 1983)). Under those circumstances, a court need “only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.” Diamond, 416 F.3d at 315 (quoting Fed. R. Civ. P. 72 advisory committee’s note). B. Standard of Review of Commissioner’s Decision Judicial review of disability cases is limited to determining whether substantial evidence supports the Commissioner’s conclusion that the plaintiff failed to meet his burden of proving disability. See Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990); see also Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966).

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Roach v. Gates
417 F. App'x 313 (Fourth Circuit, 2011)
David E. Camby v. Larry Davis James M. Lester
718 F.2d 198 (Fourth Circuit, 1983)
United States v. Nicholas Omar Midgette
478 F.3d 616 (Fourth Circuit, 2007)
Judy Moon v. BWX Technologies, Incorporated
498 F. App'x 268 (Fourth Circuit, 2012)
Aistrop v. Barnhart
36 F. App'x 145 (Fourth Circuit, 2002)
Denton v. Astrue
596 F.3d 419 (Seventh Circuit, 2010)
Howard's Yellow Cabs, Inc. v. United States
987 F. Supp. 469 (W.D. North Carolina, 1997)
Moon v. BWX Technologies, Inc.
742 F. Supp. 2d 827 (W.D. Virginia, 2010)
Bonnilyn Mascio v. Carolyn Colvin
780 F.3d 632 (Fourth Circuit, 2015)

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Ray v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ray-v-commissioner-of-social-security-vawd-2025.