Court Lets Commissioner Amend Judgment Denying Benefits

A second circuit district court permits a commissioner of Social Security to amend a recently issued decision denying disability benefits following the court’s remanding of the case. In Garcia v. Commissioner of Social Security (S.D.N.Y. 21-cv-01230, November 22, 2022).

In 2018, Rebecca Garcia, a woman diagnosed with several medical and mental health conditions, made two main requests under the Social Security Act. She sought a period of disability and disability benefits under Title II and Supplemental Security Income (SSI) under Title XVI.

The administrative law judge determined that Ms. Garcia was not disabled from her alleged onset date to the decision date. For the Title II claim, the administrative law judge decided that Ms. Garcia did not have a medically determinable impairment before losing her insurance. For the Title XVI claim, the administrative law judge found that Ms. Garcia was not disabled because she could perform past relevant work at her residual functional capacity, which reflects her current condition.

When Ms. Garcia requested a review of the decision, the Appeals Council denied it, making the administrative law judge’s decision the commissioner’s final decision.

Ms. Garcia then brought an action against the commissioner to challenge the decision denying her benefits. She did not contest the administrative law judge’s denial of a period of disability and disability benefits under Title II, only the SSI under Title XVI. Finding that the administrative law judge erred by neglecting to consider Ms. Garcia’s mental impairments when assessing her residual functional capacity, the court issued a decision remanding the case.

Under Federal Rule of Civil Procedure 59(e), which permits a district court to modify a recently issued decision, the commissioner motioned to alter the judgment. In response, Ms. Garcia filed an opposition memorandum.

According to the Second Circuit, the F.R.C.P. 59(e) allows district courts to modify judgments to fix a clear error of law or prevent obvious injustice. The change must be substantive, not just a clerical correction.

The court permits the commissioner to amend the judgment concerning the SSI analysis. As Ms. Garcia did not challenge the administrative law judge’s finding regarding her entitlement to a period of disability and disability benefits under Title II, the court stresses that its remand only reflects the SSI claim. Yet, on remand, the court may consider any relevant issues, even if Ms. Garcia did not raise them on appeal.

Read the full opinion here.