Rouzard v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedJanuary 28, 2025
Docket6:24-cv-00585
StatusUnknown

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

Bluebook
Rouzard v. Commissioner of Social Security, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

DIANSKY ROUZARD,

Plaintiff,

v. Case No: 6:24-cv-585-CEM-LHP

COMMISSIONER OF SOCIAL SECURITY,

Defendant

AMENDED1 REPORT AND RECOMMENDATION TO THE UNITED STATES DISTRICT COURT:

This cause came on for consideration without oral argument on the following motion filed herein: MOTION: MOTION TO DISMISS WITH MEMORANDUM IN SUPPORT (Doc. No. 48) FILED: October 15, 2024

THEREON it is RECOMMENDED that the motion be GRANTED.

1 Amended only to correct the docket entry number of the motion to which this report and recommendation relates. I. BACKGROUND. Diansky Rouzard, on behalf of himself and his minor children (“Plaintiff”),

appearing pro se, instituted this action against Defendant the Commissioner of Social Security (“the Commissioner”) by complaint filed on April 1, 2024. Doc. No. 1.2 On May 24, 2024, Plaintiff filed an amended complaint, which includes a form

Complaint for a Civil Case, Doc. No. 9, and a separate Civil Complaint and Demand for Jury Trial, Doc. No. 9-4. Plaintiff purports to assert claims for “breach of contract,” “breach of fiduciary duty,” and “violation of Title XVI of the Social Security Act,” based on the following:

The Plaintiff and his minor children are individuals who have been enrolled in the Social Security Disability Income (SSDI) and the Social Security Income (SSI) program, administered by the Defendant. Pursuant to Title XVI (Supplemental Security Income for the Aged, Blind, and Disabled) of the Social Security Act, the Defendant has the contractual obligation to provide financial support and assistance to Plaintiff and his minor child, [M.R.], who receives Social Security Income for benefits and delaying pending application for [A.R.]. The SSA’s inadequate processing initial application, waiver and reconsideration requests has led to months of unresolved issues. Despite Plaintiff’s efforts to communicate via letters and receiving unrecorded phone calls, the SSA failed to identify requests, continuing improper overpayment recoupment.

2 Upon review, there is a “general approbation for non-attorney parents’ pursuit of SSI benefits on behalf of their children,” see T.R.B. by & through Green v. Berryhill, No. CV419-068, 2019 WL 2202785, at *2 (S.D. Ga. May 21, 2019) (collecting authority), and thus, Plaintiff’s standing is not further addressed in this report. Due to the arbitrary and capricious practices of the SSA, resulting in financial and emotional harm by imposing wrongful penalties causing Plaintiff to receive a reduction to the maximum SSI & SSDI benefit payments. The income limit for SSI is the federal benefit rate, which is now $943 per month for SSI recipients. As a SSDI & SSI recipient, Plaintiff has not received a fair and proper adjustment due to the cost of living for 2024. All Plaintiff receives for SSDI is $405 and SSI is $558. The federal benefit rate maximum SSDI amount is $3,822.00 and the federal benefit rate maximum SSI amount is $943. SSI benefit payments in 2024 increased because Plaintiff has not received any benefit payments for [A.R.] due to her SSI benefit application being under disability review, which is extremely delayed and Plaintiff has not received the maximum benefit payments for [M.R.].

Arbitrary limitations on the 10% limitation rule led to overpayments and unfair benefit reductions, violating the Social Security Act and constitutional guarantees. As told by the SSA Agent . . . that there were concerns about SSA’s information gathering from neighbors raising privacy issues which further undermine trust. The incorrect benefit payments are causing Plaintiff and his minor children financial harm and emotional distress. The Defendant, in breach of its contractual obligations, has failed to provide the Plaintiffs with the appropriate and timely disability benefits as required under Title XVI of the Social Security Act. As a result of Defendant’s breach of contract, the Plaintiffs have suffered severe financial hardship, emotional distress, and other related damages.

See Doc. No. 9-4, at 1–2 (filed under seal)3; see also Doc. No. 9, at 3 (stating that the basis for the Court’s jurisdiction is violation of Title XVI, negligence, violation of due process, 20 C.F.R. § 416.571, and civil money penalty). Plaintiff seeks $100 million in compensatory damages, retroactive benefits, provision of disability

3 It appears that this filing was placed under seal due to the use of the minor children’s full names. See Doc. No. 9-4. Thus, the minor children’s names are redacted from the recitation provided herein. payments, a declaration regarding his entitlement to social security benefits, and other related relief. Doc. No. 9-4, at 3.

The Commissioner appeared in this case by filing a motion to dismiss for lack of subject matter jurisdiction and failure to state a claim under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), arguing that Plaintiff had failed to exhaust

administrative remedies prior to filing the complaint, which motion was supported by a declaration from a specialist for the Social Security Administration (“SSA”). Doc. No. 27; see also Doc. Nos. 25–26 (initial motion to dismiss denied without prejudice for failure to comply with Local Rule 3.01(g)). Plaintiff opposed, relying

on several of his own evidentiary submissions in support. Doc. No. 31. And the Commissioner filed an authorized reply, with an updated declaration. Doc. No. 41. Upon referral, the undersigned denied the motion without prejudice due to the

conflicting representations in the parties’ filings and supporting evidence and required supplementation to the record to address the question of exhaustion of administrative remedies based on the Commissioner’s factual attack on the Court’s subject matter jurisdiction. Doc. No. 43.4

4 A motion to dismiss for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1) may present either a facial or factual challenge to the complaint. McElmurray v. Consol. Gov’t of Augusta-Richmond Cty., 501 F.3d 1244, 1251 (11th Cir. 2007). A facial attack necessitates accepting the allegations in the complaint as true and assessing whether plaintiff has sufficiently alleged a basis for subject matter jurisdiction. Id. Factual attacks, on the other hand, allow the court to go beyond the pleadings and consider testimony and affidavits to determine whether subject matter jurisdiction exists On September 30, 2024, the Commissioner filed the Administrative Record, to exclude medical records unrelated to the overpayment issues raised in this case.

Doc. No. 47. Then, on October 15, 2024, the Commissioner renewed his motion to dismiss. Doc. No. 48. However, the Commissioner no longer asserts that the Court lacks subject matter jurisdiction, and instead, the motion is brought for failure to

state a claim under Federal Rule of Civil Procedure 12(b)(6) alone. Id. at 2. The Commissioner contends that Plaintiff has failed to allege or demonstrate that he exhausted his administrative remedies by obtaining a final decision from the Commissioner regarding the issues raised in the amended complaint, and that

Plaintiff has failed to demonstrate a valid basis to waive the exhaustion requirements. Id. at 2–10.

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