PATTERSON v. COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION (2020)
United States Court of Appeals, Fourth Circuit.
Patricia T. PATTERSON, Plaintiff-Appellant, v. COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION, Defendant-Appellee.
Decided: May 18, 2020
Before WILKINSON and MOTZ, Circuit Judges, and TRAXLER, Senior Circuit Judge.
Patricia T. Patterson, Appellant Pro Se.
Patricia T. Patterson appeals the district court's order adopting the magistrate judge's recommendation upholding the Administrative Law Judge's (ALJ) denial of Patterson's application for disability insurance benefits.* “In social security proceedings, a court of appeals applies the same standard of review as does the district court. That is, a reviewing court must uphold the determination when an ALJ has applied correct legal standards and the ALJ's factual findings are supported by substantial evidence.” Brown v. Comm'r Soc. Sec. Admin., 873 F.3d 251, 267 (4th Cir. 2017) (citation and internal quotation marks omitted).
The timely filing of specific objections to a magistrate judge's recommendation is necessary to preserve appellate review of the substance of that recommendation when the parties have been warned of the consequences of noncompliance. United States v. Midgette, 478 F.3d 616, 621-22 (4th Cir. 2007); see also Thomas v. Arn, 474 U.S. 140, 154-55, 106 S.Ct. 466, 88 L.Ed.2d 435 (1985). Because Patterson failed to file specific objections to the magistrate judge's finding that the ALJ's disability determination was supported by substantial evidence, Patterson has waived appellate review of that determination. We further find no merit to Patterson's challenges to the propriety of the proceedings below.
Accordingly, we affirm the district court's judgment upholding the denial of disability insurance benefits. See Patterson v. Comm'r of Soc. Sec. Admin., No. 9:17-cv-01899-MBS (D.S.C. filed Mar. 13, 2019 & entered Mar. 14, 2019). We grant Patterson's motion to exceed the length limitations for her informal brief but deny her motion for default judgment and requests for damages. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process.
FOOTNOTE. The ALJ, however, awarded Patterson supplemental security income.
Affirmed by unpublished per curiam opinion.
Unpublished opinions are not binding precedent in this circuit.
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