GARCIA
v.
COMMISSION OF SOCIAL SECURTIY ADMINISTRATION
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Rafael Garcia appealed a Social Security benefits decision, filing a motion for summary judgment that was opposed by the Acting Commissioner of Social Security. The district court, reviewing a magistrate judge's recommendation without objections from either party, affirmed the recommendation and granted the Commissioner's motion for summary judgment.
The Court affirmed the magistrate judge's recommendation to deny Garcia's motion for summary judgment and grant the Commissioner's motion for summary judgment, finding no clear error in the magistrate judge's analysis.
[1] A district court need only review a magistrate judge's report for clear error when no party timely objects to the report.
[2] Failure to object to a magistrate judge's factual findings after notice precludes a later attack on those findings.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligenceRafael Garcia brought suit challenging a decision by the Social Security Administration regarding his benefits eligibility. The case proceeded through…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Clear Error Standard Of Review cases and more on FLexlaw
THIS CAUSE comes before the Court upon United States Magistrate Judge Becerra's Report and Recommendation, [ECF No. 22] (“Report”), filed on December 20, 2023. The Report recommends that the Court deny Plaintiff's Motion for Summary Judgment, [ECF No. 14] ("Plaintiff's Motion”), and grant Defendant's Motion for Summary Judgment, [ECF No. 16] (“Defendant's Motion”). See Report at 1. The Report properly notified Plaintiff of his right to object to Magistrate Judge Becerra's findings. Id. at 10–11. The time for objections has passed, and there are no objections to the Report.
When a magistrate judge's “disposition” has been properly objected to, a district court must review the disposition de novo. FED. R. CIV. P. 72(b)(3). When no party has timely objected, however, “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 note to 1983 addition (citation omitted). Although Rule 72 itself is silent on the standard of review, the Supreme Court has acknowledged Congress's intent was to only require de novo review where objections
have been properly filed, not when neither 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.” (emphasis in original; alterations added)). 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)).
Because there are no objections to the Report, the Court did not conduct a de novo review. Rather, the Court reviewed the Report for clear error. Finding none, it is hereby
ORDERED AND ADJUDGED as follows:
1. The Report, [ECF No. 22], is AFFIRMED AND ADOPTED. 2. Plaintiff’s Motion, [ECF No. 14], is DENIED. 3. Defendant’s Motion, [ECF No. 16], is GRANTED. 4. Pursuant to Rule 58 of the Federal Rules of Civil Procedure, final judgment will be entered by separate order.
5. Any pending motions are DENIED as moot.
DONE AND ORDERED in Miami, Florida, this 8th day of January, 2024.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Thomas v. Arn, 474 U.S. 140 (U.S. 1985)
- Lewis v. Smith, 855 F.2d 736 (11th Cir. 1988)