D.H. v. Bisignano
- Jerry Blackwell
- 0:25-cv-01190
- U.S. District Court · District of Minnesota
- 2
In Cedrick D.H. v. Frank Bisignano, Commissioner of Social Security, Judge Blackwell accepted a magistrate judge's recommendation and affirmed the Social Security Administration's decision denying the plaintiff's claim for benefits.
Individuals who have had Social Security benefits claims denied and are appealing in federal court, particularly those whose cases are reviewed under a 'clear error' standard because no objections were filed to a magistrate judge's recommendation.
What happened
In Cedrick D.H. v. Frank Bisignano, Commissioner of Social Security (Case No. 25-1190), a plaintiff identified only by first name and last initial under a court privacy policy challenged the Social Security Administration's denial of his benefits claim in the U.S. District Court for the District of Minnesota.
United States Magistrate Judge Elsa M. Bullard issued a Report and Recommendation on January 31, 2026, recommending that the plaintiff's request for relief be denied and the government's request be granted. No party filed objections to that recommendation within the allowed time, which meant the court reviewed it only for obvious legal mistakes rather than conducting a full independent review.
Judge Jerry W. Blackwell found no clear error in the magistrate judge's Report and Recommendation, accepted it in full, denied the plaintiff's request for relief, granted the defendant Commissioner's request for relief, and affirmed the Social Security Administration's underlying decision. Judgment is to be entered accordingly.
The detailed version
Case
Cedrick D.H. v. Frank Bisignano, Commissioner of Social Security, Civ. No. 25-1190 (JWB-EMB), U.S. District Court, District of Minnesota.
Judge
United States District Judge Jerry W. Blackwell. The underlying Report and Recommendation (R&R) was issued by United States Magistrate Judge Elsa M. Bullard.
Background
The plaintiff, identified only as 'Cedrick D.H.' pursuant to the District of Minnesota's privacy policy for Social Security appellants, filed suit challenging a decision by the Commissioner of Social Security. The nature of the specific benefits claim (e.g., disability insurance, supplemental security income) is not described in this order.
Procedural History
Magistrate Judge Bullard issued a Report and Recommendation on January 31, 2026, recommending denial of the plaintiff's request for relief (Doc. No. 9) and granting of the Commissioner's request for relief (Doc. No. 12). No objections to the R&R were filed within the time permitted by Federal Rule of Civil Procedure 72(b).
Standard of Review
Because no timely objections were filed, Judge Blackwell reviewed the R&R only for 'clear error,' a deferential standard that requires the reviewing judge to accept the magistrate's findings unless they are plainly incorrect. This is a lower level of scrutiny than the de novo (fresh, independent) review that would apply if objections had been filed. The court cited Fed. R. Civ. P. 72(b) and Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996).
Ruling: Judge Blackwell found no clear error and, on February 24, 2026:
- Accepted the January 31, 2026 R&R;
- Denied the plaintiff's request for relief;
- Granted the Commissioner's request for relief; and
- Affirmed the Commissioner's underlying Social Security decision.
Judgment is to be entered in favor of the defendant Commissioner.
Effect
The Social Security Administration's denial of the plaintiff's benefits claim stands as affirmed. The specific reasoning behind the denial is contained in the R&R (Doc. No. 15), which is not reproduced in this order.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.