September L. v. Bisignano
- Laura Provinzino
- 0:25-cv-00331
- U.S. District Court · District of Minnesota
- 2
In September L. v. Frank Bisignano, Commissioner of Social Security, Judge Provinzino adopted a magistrate judge's recommendation and ordered that September L.'s disability insurance benefits case be sent back to the Social Security Administration for further review after finding the agency's denial was flawed.
Individuals who have been denied Social Security disability insurance benefits and are seeking judicial review of the agency's decision, particularly those whose claims involve nonsevere mental impairments that the agency may not have fully considered.
What happened
In September L. v. Frank Bisignano, Commissioner of Social Security, a Minnesota federal court considered whether the Social Security Administration (SSA) wrongly denied disability insurance benefits to the plaintiff, September L. September L. asked the court to throw out the SSA's denial and send the case back to the agency for another look, while the Commissioner argued the denial should be upheld.
United States Magistrate Judge Elizabeth Cowan Wright had previously issued a detailed report on January 29, 2026, recommending that the case be sent back to the SSA. The magistrate judge found that, among other issues, the agency had failed to properly account for September L.'s mental impairments — which were found not to be severe on their own — when making its overall disability determination. Neither party objected to that report.
Judge Provinzino reviewed the magistrate judge's report and found no errors, adopting it in full. The court granted September L.'s request to remand (send back) the case to the SSA for further proceedings, denied the Commissioner's request to dismiss the complaint, and directed the agency to properly address September L.'s nonsevere mental impairments and the other errors she had raised.
The detailed version
Case
September L. v. Frank Bisignano, Commissioner of Social Security, No. 25-cv-331 (LMP/ECW), U.S. District Court for the District of Minnesota.
Judge
Laura M. Provinzino, United States District Judge.
Background
Plaintiff September L. brought this action seeking judicial review of a final administrative decision by the Commissioner of Social Security denying her application for disability insurance benefits (DIB) under the Social Security Act. She asked the court to vacate the Commissioner's decision and remand the matter for further administrative proceedings. The Commissioner opposed her request and asked the court to affirm the denial and dismiss the complaint.
Magistrate Judge's Report and Recommendation (R&R)
United States Magistrate Judge Elizabeth Cowan Wright issued an R&R on January 29, 2026, recommending that September L.'s request for remand be granted and that the Commissioner's request to dismiss be denied. The R&R identified that the agency failed to account for September L.'s nonsevere mental impairments in its overall disability analysis, and found other claims of error that warranted remand. A footnote in the final order confirms that on remand the Commissioner must address both the nonsevere mental impairments issue and September L.'s other raised claims of error.
Standard of Review
Because neither party filed objections to the R&R within the applicable period, the district court reviewed it under the clear error standard. See Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996). Finding no clear error, Judge Provinzino adopted the R&R in full.
Disposition: The court:
- Adopted the R&R (ECF No. 14);
- Granted September L.'s request for remand (ECF Nos. 8, 11);
- Denied the Commissioner's request to dismiss the complaint (ECF No. 10); and
- Remanded the case to the Commissioner pursuant to sentence four of 42 U.S.C. § 405(g) — a statutory provision authorizing courts to affirm, modify, or reverse SSA decisions, with or without remand — for further administrative proceedings consistent with the R&R.
Judgment was ordered to be entered accordingly.
Practical effect
The SSA must reconsider September L.'s disability claim and correct the identified errors, including properly weighing her nonsevere mental impairments as part of the full disability evaluation.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.