Franz v. Bisignano
- Jeffrey Bryan
- 0:24-cv-02795
- U.S. District Court · District of Minnesota
- 2
In Franz v. Bisignano, Judge Jeffrey M. Bryan adopted a magistrate judge's recommendation and dismissed without prejudice the Social Security disability benefits appeal brought by plaintiff Michelle F., upholding the Commissioner's decision to deny her benefits.
Individuals who have been denied Social Security benefits and are appealing that denial in federal court, particularly those whose cases are resolved at the magistrate judge recommendation stage without objection.
What happened
In Franz v. Bisignano (Case No. 24-CV-02797), plaintiff Michelle F. sued Frank Bisignano, the Commissioner of Social Security, asking a federal court to overturn the agency's decision to deny her Social Security benefits. The case was referred to a magistrate judge — a judicial officer who assists the main judge — who issued a Report and Recommendation on July 31, 2025, advising that Michelle F.'s request be denied and the agency's decision be upheld. Neither party objected to that recommendation within the allowed time.
Because no objections were filed, Judge Jeffrey M. Bryan was only required to review the magistrate judge's Report and Recommendation for clear, obvious errors — a lower level of review than if objections had been raised. Finding no such errors, the court accepted the recommendation in full.
Judge Jeffrey M. Bryan issued an order on August 28, 2025, adopting the Report and Recommendation and dismissing the case without prejudice, meaning Michelle F. is not automatically barred from filing again, though the opinion does not explain the basis for dismissal without prejudice rather than a judgment on the merits.
The detailed version
In this Social Security appeal, plaintiff Michelle F. challenged the Social Security Administration's (SSA) denial of her benefits by filing suit against the Commissioner of Social Security, Frank Bisignano, in the United States District Court for the District of Minnesota.
The case was referred to United States Magistrate Judge Shannon G. Elkins, who issued a Report and Recommendation (R&R) on July 31, 2025. The R&R recommended that Michelle F.'s request for relief be denied and that the Commissioner's decision to deny benefits be upheld. Under Local Rule 72.2(b)(1), parties had a period of time to file objections to the R&R, but neither Michelle F. nor the Commissioner did so.
In the absence of timely objections, District Judge Jeffrey M. Bryan applied the deferential 'clear error' standard of review, as required by Federal Rule of Civil Procedure 72(b) and the Eighth Circuit's decision in Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996). Under this standard, the court does not re-examine the issues anew but only looks for obvious mistakes in the magistrate judge's analysis.
Finding no clear error, Judge Bryan adopted the R&R and dismissed the action without prejudice. The dismissal is 'without prejudice,' meaning it does not formally bar Michelle F. from future proceedings, though the opinion does not elaborate on why the case was dismissed without prejudice rather than resolved with a judgment on the merits affirming the SSA's denial. Judgment was entered accordingly on August 28, 2025.
Note: The plaintiff is identified only as 'Michelle F.' pursuant to a District of Minnesota policy of using only the first name and last initial of non-governmental parties in Social Security cases. The case caption is styled Franz v. Bisignano based on the case metadata.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.