Victoria H. v. Bisignano
- Elizabeth Wright
- 0:25-cv-00847
- U.S. District Court · District of Minnesota
- 2
In Victoria H. v. Frank Bisignano, Commissioner of Social Security, Judge Jeffrey M. Bryan adopted a magistrate judge's recommendation and granted the plaintiff's request to reverse the Social Security Administration's denial of disability insurance benefits.
Individuals who have had their Social Security Disability Insurance (Title II) benefit claims denied by the Social Security Administration and are seeking judicial review of that denial, particularly those whose cases are pending in the District of Minnesota.
What happened
In Victoria H. v. Frank Bisignano, Commissioner of Social Security (Case No. 25-CV-00847), a Minnesota federal court considered a challenge to the Social Security Administration's decision to deny Victoria H. disability insurance benefits under Title II of the Social Security Act. The case had been referred to Magistrate Judge Elizabeth Cowan Wright, who issued a Report and Recommendation on January 30, 2026, recommending that the plaintiff's request to reverse the denial of benefits be granted and that the Commissioner's request to affirm the denial and dismiss the case be denied.
Neither party objected to the magistrate judge's Report and Recommendation within the required time period. When no objections are filed, the district court reviews the report only for clear error — meaning an obvious mistake — rather than conducting a full independent review.
Finding no clear error, Judge Jeffrey M. Bryan adopted the Report and Recommendation in full on February 17, 2026. The court granted Victoria H.'s motion to reverse the Commissioner's denial of benefits, denied the Commissioner's motion to affirm, and dismissed the action without prejudice — meaning the case is closed but could potentially be refiled.
The detailed version
This case arises from a challenge to the Social Security Administration's (SSA) denial of Title II Disability Insurance Benefits (DIB) to plaintiff Victoria H. Title II DIB provides monthly payments to individuals who have worked and paid Social Security taxes but have become disabled and can no longer work.
The case was referred to United States Magistrate Judge Elizabeth Cowan Wright pursuant to 28 U.S.C. § 636, which allows district courts to assign certain matters to magistrate judges. On January 30, 2026, Magistrate Judge Wright issued a Report and Recommendation (R&R) recommending: (1) that Victoria H.'s motion to reverse the Commissioner's denial of benefits be granted; and (2) that the Commissioner's motion to affirm the denial and dismiss the action be denied.
Pursuant to District of Minnesota Local Rule 72.2(b)(1), the parties had a set period to file objections to the R&R. Neither party objected. Under Federal Rule of Civil Procedure 72(b) and Eighth Circuit precedent (Grinder v. Gammon, 73 F.3d 793 (8th Cir. 1996)), when no timely objections are filed, the district court reviews the R&R only for 'clear error' — a deferential standard that looks for obvious mistakes rather than conducting a full de novo (independent) review.
Judge Jeffrey M. Bryan found no clear error in the R&R and adopted it in full on February 17, 2026. The court: (1) adopted the R&R (Doc. No. 17); (2) granted Plaintiff Victoria H.'s motion (Doc. No. 9) to reverse the Commissioner's denial of benefits; (3) denied the Commissioner's motion (Doc. No. 14) to affirm and dismiss; and (4) dismissed the action without prejudice. The dismissal without prejudice means the case is closed in its current form but does not permanently bar refiling.
Note: The opinion does not specify the grounds on which Magistrate Judge Wright recommended reversal, as the detailed analysis would be contained in the R&R itself, which is not reproduced here. The district court's order is limited to adopting that recommendation upon a clear-error review.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.