Stephanie Martini v. Commissioner of Social Security

District Court, M.D. Florida·Decided September 9, 2026·No. 8:25-cv-03079·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

STEPHANIE MARTINI,

Plaintiff,

v. Case No. 8:25-cv-3079-KKM-TGW

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

ORDER Stephanie Martini appeals a decision by the Commissioner of Social Security denying her claim for disability benefits and moves for remand under Sentences Four and Six of 42 U.S.C. § 405(g). See Mem. (Doc. 19); Mot. (Doc. 25). Martini generally argues that remand is warranted under Sentence Four on grounds that the agency misapplied controlling legal standards and did not consider the combined effect of the evidence, see Mem., and under Sentence Six so that she may add purportedly new and noncumulative evidence that she failed to incorporate in the administrative record with good cause, see Mot. The agency opposes. Opp. (Doc. 21). The magistrate judge recommends that I deny Martini’s motion for remand under Sentence Six. R&R (Doc. 29). Martini objects, arguing that the magistrate judge mistakenly concluded that the evidence Martini wants to add to the record is immaterial. Obj. (Doc. 32). On review of the Report and

Recommendation, I find no reversible error. The magistrate judge did not consider the Sentence Four argument that Martini raised in a separately filed memorandum. Martini contends that this argument is pending before the Court. Obj. at 1. I consider Martini’s Sentence

Four argument and conclude that the agency did not misapply the law and that substantial evidence supports the agency’s conclusions. Accordingly, I adopt the Report and Recommendation as to Martini’s Sentence Six argument and deny the motion to remand.

I. BACKGROUND Martini filed a claim for disability-insurance benefits in January 2022, alleging disability due to cervical and lumber stenosis, bulging discs on her back and neck, radiculopathy, sciatic nerve damage, chronic headaches,

anxiety, and numbness in legs, feet, and hands due to radiculopathy. Tr. (Docs. 15, 15-1–9) at 127, 135, 271. She alleged that these disabilities began December 26, 2021. Id. at 10, 127, 135, 231–32. The agency denied her claim initially and on reconsideration, id. at 10,

127–33, 135–47, and an administrative law judge (ALJ) affirmed the agency’s decision on March 3, 2025, after holding an administrative hearing, id. 10–28, 100–25. The ALJ found that Martini was not disabled under the agency’s five- step sequential evaluation process. Id. at 10–28; see 20 C.F.R. § 404.1520(a)(4).

The ALJ found that Martini had “not engaged in substantial gainful activity since” her alleged onset date, Tr. 12, had the severe impairments of “degenerative disc disease of the cervical and lumbar spine[,] generalized anxiety disorder[,] major depressive disorder[,] and post-traumatic stress

disorder,” id., and did “not have an impairment or condition of impairments that meets or medically equals the severity of one of the listed impairments” in 20 C.F.R. Part 404, Subpart P, Appendix 1, id. at 13. The ALJ also found that Martini “is unable to perform any past relevant work,” id. at 19, but “has

the residual functional capacity to perform light work” as defined in 20 C.F.R. § 404.1567(b) with certain limitations, id. at 15. After the ALJ concluded that Martini was not disabled under the Social Security Act from her December 2021 alleged onset date through March 3,

2025, id. at 21–22, Martini sought review by the Appeals Council, id. at 1–5, 10, 227–229. The Appeals Council denied her request. Id. Martini then filed her complaint for review in this Court. She moved for remand under Sentence Six of 42 U.S.C. § 405(g), (Doc. 18), and, on the same

day, filed a separate memorandum in support of remand under Sentence Four, along with four medical records that she failed to incorporate in the record before the agency, Mem.; Suppl. (Doc. 20). A month later, she filed a supplement with another medical record that she failed to incorporate in the record before the agency. Suppl. Martini later filed an amended motion to

remand to correct her failure to sign the original motion. See Mot. After Martini’s Sentence Six motion was fully briefed, the magistrate judge issued a Report and Recommendation recommending that I deny it. See R&R. The Report and Recommendation did not address Martini’s separate

memorandum or supplement under Sentence Four. Martini now objects to the Report and Recommendation as to her motion and urges that the argument she made in her separate memorandum is properly before this Court.

II. STANDARDS OF REVIEW A. Review of a Magistrate Judge’s Report and Recommendation After conducting a careful and complete review of the findings and recommendations, a district judge may accept, reject, or modify a magistrate judge’s Report and Recommendation. 28 U.S.C. § 636(b)(1). If a party files a timely and specific objection to a finding of fact by a magistrate judge, the

district court must review that factual issue de novo. Stokes v. Singletary, 952 F.2d 1567, 1576 (11th Cir. 1992). The district court reviews legal conclusions de novo, even in the absence of an objection. See Cooper-Houston v. S. Ry. Co., 37 F.3d 603, 604 (11th Cir. 1994); Ashworth v. Glades Cnty. Bd. of Cnty.

Comm’rs, 379 F. Supp. 3d 1244, 1246 (M.D. Fla. 2019). B. Review of an Administrative Law Judge’s Disability Determination A court “reviews[] de novo the ALJ’s application of legal principles” and “the ALJ’s resulting decision ‘to determine whether it is supported by

substantial evidence.’ ” Buckwalter v. Acting Comm’r, 5 F.4th 1315, 1320 (11th Cir. 2021) (quoting Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005) (per curiam)). “Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains ‘sufficien[t]

evidence’ to support the agency’s factual determinations.” Biestek v. Berryhill, 587 U.S. 97, 102 (2019) (quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). Substantial evidence is “more than a mere scintilla” but “means— and means only—‘such relevant evidence as a reasonable mind might accept

as adequate to support a conclusion.’ ” Id. (quoting Consol. Edison, 305 U.S. at 229)). So, even if the preponderance of the evidence weighs against the ALJ’s determination, the court “must affirm if the decision reached is supported by substantial evidence.” Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155, 1158–

59 (11th Cir. 2004) (quoting Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990)). III. LEGAL STANDARDS “An individual claiming Social Security disability benefits must prove

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