Case Name in Social Security Case - Unavailable

United States District Court
Eastern District of New York
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MARIA ESTHER REYES,
Plaintiff,
- against -
COMMISSIONER OF SOCIAL SECURITY,
Defendant.
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Memorandum & Order
No. 18-CV-981 (KAM)
Kiyo A. Matsumoto, United States District Judge:
Before this Court is Plaintiff’s Motion to Enforce Judgment
and the government’s response to Plaintiff’s motion. Plaintiff
argues that the Commissioner of the Social Security Administration
has not complied with this Court’s November 25, 2019 Memorandum
and Order and the November 26, 2019 Judgment finding that the
Social Security Administration Administrative Law Judge applied
the incorrect legal standard for reviewing an applicant’s residual
functional capacity (RFC) when reviewing Plaintiff’s disability
insurance benefits and supplemental security insurance benefits
application. The government, however, argues that Plaintiff is
effectively repeating her argument from the related case, Reyes v.
Commissioner of Social Security, 23-CV-8448, where Plaintiff
argued that the ALJ incorrectly identified her disability onset
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date as September 11, 2007. In that case, however, this Court
found that Plaintiff received a favorable decision approving her
SSI application, so the Court lacked subject matter jurisdiction
over the action. For the reasons provided below, the Court denies
Plaintiff’s motion to enforce judgment and dismisses this action
with prejudice.
BACKGROUND
The Court assumes the parties’ familiarity with the facts and
procedural history of this case, which were explained in this
Court’s December 27, 2024 Memorandum & Order in a related case,
Reyes v. Commissioner of Social Security, 772 F. Supp. 3d 278
(E.D.N.Y. 2024), and, therefore, discusses the facts and
procedural history relevant to the instant motion to enforce
judgment before the Court.
On November 26, 2019, this Court remanded this case to the
Social Security Administration Administrative Law Judge (“ALJ”) to
determine if Plaintiff Maria Esther Reyes (“Plaintiff” or “Ms.
Reyes”) was disabled and eligible for disability insurance
benefits (“DIB”) and supplemental security income (“SSI”) after
determining that the ALJ’s decision did not properly apply the
legal standard by not providing a function-by-function analysis to
formulate Plaintiff’s RFC and failing to incorporate findings as
to Plaintiff’s ability to complete certain daily activities. (ECF
No. 24, Memorandum and Order dated November 25, 2019 (“2019 M&O”).)
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On November 3, 2023, Plaintiff sued the Commissioner of the Social
Security Administration (“Defendant”) and other parties in a
related case to challenge the decision of an ALJ determining that
Plaintiff’s disability onset date was September 11, 2007 and
approving Plaintiff’s application for SSI. (Reyes v. Commissioner
of Social Security, 1:23-cv-8448 (Reyes II), ECF No. 1.) The Court
found that it lacked subject matter jurisdiction over Plaintiff’s
complaint because the Court could not review a favorable decision
from the ALJ. (Reyes II, ECF No. 34.)
On May 28, 2026, Plaintiff filed a motion to enforce judgment
in this case. (ECF No. 28, Motion to Enforce Judgment (“Pl.’s
Mot.”).) On June 2, 2026, the Court ordered the government to
respond by June 10, 2026. (Order dated 06/02/2026.) The
government timely filed its response on June 10, 2026. (ECF No.
31, Response to Motion to Enforce Judgment (“Def.’s Resp.”).)
LEGAL STANDARD
Plaintiff submitted her motion to enforce judgment pro se, so
the Court must construe Plaintiff’s submission “liberally” and
interpret it to “raise the strongest arguments that [it]
suggest[s].” Saeli v. Chautauqua County, NY, 36 F.4th 445, 457
(2d Cir. 2022) (quoting Triestman v. Fed. Bureau of Prisons, 470
F.3d 471, 474 (2d Cir. 2006)).
“Once a matter has been litigated and decided, a party may be
foreclosed from litigating the same issue again.” Kulak v. City
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of New York, 88 F.3d 63, 71 (2d Cir. 1996). Issue preclusion, or
collateral estoppel, “bars litigation of an issue when (1) the
identical issue was raised in a previous proceeding; (2) the issue
was actually litigated and decided in the previous proceeding; (3)
the party had a full and fair opportunity to litigate the issue;
and (4) the resolution of the issue was necessary to support a
valid and final judgment on the merits.” Proctor v. LeClaire, 715
F.3d 402, 414 (2d Cir. 2013) (quoting Ball v. A.O. Smith Corp.,
451 F.3d 66, 69 (2d Cir. 2006)). Though “dismissal for lack of
subject matter jurisdiction is not an adjudication of the merits,
and hence has no claim preclusive effect,” Aran v. Dep’t of
Treasury, 22-CV-904 (EK) (LB), 2023 WL 3728204, at *1 (E.D.N.Y.
May 30, 2023) (quoting St. Pierre v. Dyer, 208 F.3d 394, 400 (2d
Cir. 2000) (citation modified)), “the doctrine of issue
preclusion, or collateral estoppel, bars relitigation of the
specific issues that the prior court decided in reaching its
jurisdictional determination.” Id. (quoting Bank v. Spark Energy
Holdings, LLC, No. 13-CV-6130, 2014 WL 2805114, at *4 (E.D.N.Y
June 20, 2014) and citing Stengel v. Black, 486 F.App’x 181, 183
(2d Cir. 2012) (citation modified)).
ANALYSIS
Plaintiff argues that this Court’s 2019 M&O acknowledged that
Plaintiff’s disability “dat[ed] back to 2001 and direct[ed] the
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SSA to properly review [Plaintiff’s] case.” (Pl.’s Mot. at 3.)1
Plaintiff is partly mistaken. The Court did not, indeed could
not, determine the onset date of Plaintiff’s disability in its
review of the ALJ’s decision. Rather, the Court determined that
the ALJ did not apply the proper legal standard and so remanded
the case to the ALJ to apply the correct legal standard. (ECF No.
24.) The ALJ must determine the disability onset date, not the
district court.
The Court, therefore, understands Plaintiff’s actual argument
to be that, on remand, the ALJ incorrectly determined Plaintiff’s
disability onset date. But the Court addressed that decision of
the ALJ in its December 27, 2024 M&O. Reyes, 772 F. Supp. 3d 278.
Thus, the Court agrees with the government that Plaintiff’s motion
to enforce judgment is barred by issue preclusion because the issue
of jurisdiction has already been decided. (Def.’s Resp. at 4–5.)
Plaintiff received a favorable decision from the ALJ, and this
Court may not review an ALJ’s decision that resolved a party’s
application in her favor. Calderon v. Astrue, 683 F. Supp. 2d
273, 276–77 (E.D.N.Y. 2010).
1 Unless otherwise noted, pincites refer to the page number generated by CM/ECF.
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CONCLUSION
For the reasons provided above, Plaintiff’s motion to enforce
judgment is DENIED and the action is dismissed with prejudice.
So ordered.
Dated: October 13, 2026
Brooklyn, New York _______________________________
Kiyo A. Matsumoto
United States District Judge
Eastern District of New York
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