Brent R. v. Bisignano
- Katherine Menendez
- 0:25-cv-01563
- U.S. District Court · District of Minnesota
- 2
In Brent R. v. Bisignano, Judge Menendez accepted a magistrate judge's recommendation and remanded the Social Security disability case for further agency review.
People who have had Social Security benefit claims denied and are appealing in federal court. This order shows that when a magistrate judge recommends remanding a case to the agency and neither side objects, the district court will typically accept that recommendation under a limited 'clear error' review standard.
What happened
In Brent R. v. Frank Bisignano, Commissioner of Social Security Administration (No. 25-cv-1563), a Minnesota federal court reviewed a Social Security benefits dispute in which the plaintiff, identified only as Brent R., challenged a decision by the Social Security Administration. The case had been referred to Magistrate Judge Leo I. Brisbois, who issued a Report and Recommendation on May 26, 2026, recommending that the plaintiff's request for relief be granted and that the case be sent back to the Social Security Administration for further proceedings. Neither side filed objections to that recommendation by the June 9, 2026 deadline.
Because no objections were filed, the court reviewed the magistrate judge's Report and Recommendation only for clear error — a limited standard of review that looks for obvious mistakes rather than conducting a full independent analysis. The court found no clear error in the magistrate judge's reasoning or conclusions.
Judge Katherine Menendez accepted the Report and Recommendation, granted Brent R.'s request for relief, denied the Commissioner's request for relief, and remanded the case to the Social Security Administration under a specific federal statute (42 U.S.C. § 405(g), sentence four) for further administrative proceedings consistent with the Report and Recommendation.
The detailed version
- Brent R. v. Bisignano · No. 0:25-cv-01563
- Katherine Menendez
- June 18, 2026
Background
Plaintiff Brent R. (identified only by first name and last initial pursuant to the District of Minnesota's policy for nongovernmental parties in Social Security cases) brought this action against the Commissioner of the Social Security Administration, Frank Bisignano. The nature of the underlying Social Security claim — for example, disability insurance benefits or supplemental security income — is not described in this order. The case was assigned to United States District Judge Katherine Menendez, with United States Magistrate Judge Leo I. Brisbois presiding over pre-trial proceedings.
Report and Recommendation
On May 26, 2026, Magistrate Judge Brisbois issued a Report and Recommendation (R&R). The R&R recommended (1) granting the plaintiff's request for relief and (2) remanding the case to the Social Security Administration for further administrative proceedings. The specific legal grounds for that recommendation are not set out in this order; the order references the R&R itself for those details.
Review Standard
The deadline for either party to file written objections to the R&R was June 9, 2026, under the District of Minnesota's Local Rule 72.2(b)(1). Neither party objected. When no objections are filed to a magistrate judge's R&R, the district court reviews the R&R only for clear error — a deferential standard that does not require the court to re-examine the R&R independently but only to identify obvious mistakes. The court cited Nur v. Olmsted Cnty., 563 F. Supp. 3d 946, 949 (D. Minn. 2021), and Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996), for this standard.
Ruling
Judge Menendez found no clear error in the R&R and issued the following orders:
- The R&R (Dkt. 26) is accepted.
- Plaintiff's request for relief (Dkt. 18) is granted as set forth in the R&R.
- Defendant's request for relief (Dkt. 24) is denied as set forth in the R&R.
- The case is remanded to the Social Security Administration pursuant to sentence four of 42 U.S.C. § 405(g) for further administrative proceedings consistent with the R&R.
A sentence-four remand under 42 U.S.C. § 405(g) is a judicially ordered return of the case to the agency for additional review. The court also directed that judgment be entered accordingly.
What This Means
The Social Security Administration's prior decision in this case is not allowed to stand as-is. The agency must conduct further administrative proceedings in line with the guidance in Magistrate Judge Brisbois's R&R. The order does not itself award benefits; it returns the matter to the agency for reconsideration.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.