AILEEN LISABETH PIEDRA
v.
COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION
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Aileen Lisabeth Piedra appealed the Social Security Administration's denial of her disability benefits claim. The District Court adopted the Magistrate Judge's recommendation to reverse and remand the Commissioner's decision for further proceedings, finding no clear error in the administrative record.
The District Court accepted and adopted the Magistrate Judge's Report and Recommendation in full, granting Piedra's Motion for Summary Judgment, denying the Commissioner's Motion for Summary Judgment, and reversing and remanding the administrative decision for further proceedings consistent with the Magistrate Judge's findings.
“the court need only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation”
Establishes the standard of review applicable when no party objects to a magistrate judge's recommendation
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Join FLexlaw to unlock all legal intelligencePiedra filed a complaint seeking judicial review of the Commissioner's denial of her disability benefits claim. The parties filed cross-motions for su…
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Our Plaintiff—Aileen Lisabeth Piedra—filed a Complaint [ECF No. 1] seeking review of the Commissioner of the Social Security Administration' denial of her claim for disability benefits. See generally Complaint. We referred the matter to U.S. Magistrate Judge Shaniek Maynard for a Report and Recommendation. See Order of Referral [ECF No. 13]. The parties then filed cross-motions for Summary Judgment. See Plaintiffs Motion for Summary Judgment [ECF No. 14]; Defendant's Motion for Summary Judgment [ECF No. 16]. The Plaintiff subsequently replied to the Defendant's Motion for Summary Judgment ("Reply") [ECF No. 17]. On October 18, 2025, Magistrate Judge Maynard issued a report and recommendation, in which she recommended that the “Plaintiff's Motion for Summary Judgment be GRANTED; that [the] Defendant's Motion for Summary Judgment be DENIED; and that the Defendant's final administrative decision be REVERSED AND REMANDED for further proceedings consistent with the finding made in this report.” Report and Recommendation (the “R&R”) [ECF No. 18] at 15. Magistrate Judge Maynard also issued the following warning:
The parties shall have fourteen (14) days from the date of being served with a copy of this Report and Recommendation within which to file written objections, if any, with U.S. District Judge Roy K. Altman. Failure to timely file objections shall bar the parties
from a de novo determination by the District Judge of an issue covered in the Report and Recommendation and shall bar the parties from attacking on appeal unobjectedto factual and legal conclusions contained in this Report and Recommendation
Id. at 16. On November 5, 2025, the Defendant filed its Notice of Non-Objection [ECF No. 19], telling us that it “does not plan on objecting to the Report and Recommendation issued in this case.” Id. at 1. More than fourteen days have passed, and the Plaintiff hasn't objected. See generally Docket. When a magistrate judge's “disposition” has been properly objected to, district courts must review that disposition de novo. FED. R. CIV. P. 72(b)(3). But, when no party has timely objected, “the court need only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.” FED. R. CIV. P. 72 advisory committee's notes (citation omitted). Although Rule 72 itself is silent on the standard of review, the Supreme Court has acknowledged that Congress's intent was to require de novo review only where objections have been properly filed—and not, as here, when no party objects. See Thomas v. Arn, 474 U.S. 140, 150 (1985) (“It does not appear that Congress intended to require district court review of a magistrate [judge]'s factual or legal conclusions, under a de novo or any other standard, when neither party objects to those findings.”). In any event, the “[f]ailure to object to the magistrate [judge]'s factual findings after notice precludes a later attack on these findings.” Lewis v. Smith, 855 F. 2d 736, 738 (11th Cir. 1988) (citing Nettles v. Wainwright, 677 F. 2d 404, 410 (5th Cir. 1982)).
Having reviewed the R&R, the record, and the applicable law—and finding no clear error on the face of the R&R—we hereby ORDER and ADJUDGE as follows:
1. The Report and Recommendation [ECF No. 18] is ACCEPTED and ADOPTED in full.
2. The Plaintiff's Motion for Summary Judgment [ECF No. 14] is GRANTED.
3. The Defendant's Motion for Summary Judgment [ECF No. 16] is DENIED.
4. The administrative decision below is REVERSED and the case is REMANDED to the Commissioner for further proceedings consistent with Judge Maynard's Report.
5. The Clerk of Court is directed to CLOSE this case. All other pending motions are DENIED as moot. And all deadlines are TERMINATED.
DONE AND ORDERED in the Southern District of Florida on November 19, 2025.
ROY K. ALTMAN
UNITED STATES DISTRICT JUDGE
cc: counsel of record
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Citator
Authorities Cited
- Thomas v. Arn, 474 U.S. 140 (U.S. 1985)
- Ennis Nettles v. Louie L. Wainwright, 677 F.2d 404 (5th Cir. 1982)
- Lewis v. Smith, 855 F.2d 736 (11th Cir. 1988)