Sykes v. Commissioner of Social Security

CourtDistrict Court, W.D. Virginia
DecidedFebruary 27, 2025
Docket4:23-cv-00025
StatusUnknown

This text of Sykes v. Commissioner of Social Security (Sykes 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
Sykes v. Commissioner of Social Security, (W.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGIN □□□ orrice us. □□□□□□□□ court ROANOKE DIVISION AT ROANOKE, VA FILED GENEAN &., 0/b/o Z.S., ) FEB 27 A MINOR CHILD, ) | □□□□ ‘att tart ‘ . LAURA A. 4 Plaintiff Civil Action No. 4:23-CV-25 Tet" ERK pePuTY CLERK v. . ) ) LELAND DUDEK, Acting ) Commissioner of Social Security,! -) By: Michael F. Urbanski ) Senior United States District Judge Defendant ) MEMORANDUM OPINION This social security disability appeal was filed by Plaintiff Genean S. (Genean) on behalf of her minor child, Z.S. 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 29, 2025, recommending that the court affirm the Commissionetr’s final decision and dismiss the case from the court’s active docket. ECF No. 18. Genean has filed objections to the R&R, ECF No. 19. As discussed below, the court declines to adopt the R&R, □ VACATES the determination by the Commissioner, and REMANDS this case to the Commissioner pursuant to sentence four of 42 U.S.C. § 405(g) for further consideration.

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 US.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 reasonably 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 court may accept, reject, or modify the recommended disposition; receive further evidence; or return the matter to the magistrate judge with instructions.” Fed. R. Civ. P. 72(b)(3); 28 U.S.C. § 636(b)(1). If, however, a party “‘makes general or conclusoty 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 (W.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 v. 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(6)(1) does not

countenance a form of generalized objection to cover all issues addressed by the magistrate judge; it contemplates that a patty’s objection to a magistrate judge’s report be specific and patticularized, 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 genetal objections “have the same effect as a failure to object, or as a waiver of such objection.” Moon v. BWX Technologies, 742 F, Supp. 2d 827, 829 (W.D. Va. 2010), affd, 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 novo 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 ITI. 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’t 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)). See also Laurie D. v. Saul, No. 1:20-cv-831 (RDB/TCB), 2022 WL 1093265, at *1 (E.D. Va. Apr. 11, 2022) (quoting Lee v. Saul, No. 2:18-cv-214, 2019 WL 3557876, at *1 (E.D. Va. Aug. 5, 2019)) (“In the event a plaintiffs ‘objections’ merely restate her prior arguments, the Court ‘need only review the Report and Recommendation using a ‘clear error’ standard.”’) Thus, in the absence of an objection, 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.

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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)
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)
Bonnilyn Mascio v. Carolyn Colvin
780 F.3d 632 (Fourth Circuit, 2015)
Stacy Lewis v. Nancy Berryhill
858 F.3d 858 (Fourth Circuit, 2017)
Anthony Martin v. Susan Duffy
858 F.3d 239 (Fourth Circuit, 2017)

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