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Chiappa v. Califano

United States District Court, S.D. New York
Dec 3, 1979
480 F. Supp. 856 (S.D.N.Y. 1979)

Summary

holding that the plaintiff overcame the presumption of notice by presenting affirmative evidence that the notice was mailed to a house that the plaintiff sold and was no longer living in

Summary of this case from Ramirez v. Colvin

Opinion

No. 78 Civ. 4213.

December 3, 1979.

Zwerling Zwerling, New York City, for plaintiff; Linda Strumpf, New York City, of counsel.

Robert B. Fiske, Jr., New York City, U.S. Atty. for the Southern Dist. of New York, for defendant; John M. O'Connor, New York City, of counsel.


The defendant moves to dismiss the complaint in this disability case on the ground that it was filed on September 7, 1978, more than sixty days after notice of the Secretary of HEW's decision was mailed to plaintiff. Social Security Act §§ 205(g) (h), 42 U.S.C. § 405(g) (h). The notice was mailed on June 27, 1978, some seventy days before the complaint was filed.

The time limit set forth in the Act is potentially a bar to any relief. Califano v. Sanders, 430 U.S. 98, 97 S.Ct. 980, 51 L.Ed.2d 192 (1977). By regulation, however, the Secretary has interpreted "mailing" to mean the date an individual receives notice of the Appeals Council's denial of his or her request for review. The date of receipt is presumed to be five days after the day on which notice is mailed, "unless there is a reasonable showing to the contrary." 20 C.F.R. § 422.210(c). In this case, therefore, the date of presumed receipt is July 2, 1978, or sixty-five days before the complaint was filed.

Plaintiff claims to have made a reasonable showing to contradict the presumption of receipt within five days of mailing. He has filed an affidavit in which he affirms that during June 1978, he sold the house in which he lived at the time he filed his administrative appeal. He moved temporarily to a summer cottage in Hancock, New York on or about June 7. The notice of denial, which was mailed to plaintiff's earlier address, was forwarded to Hancock, but it reached there on July 13. This last fact is shown, first, by a notation on the notice as follows: "Received in Hancock, N.Y. July 13, 1978. RR Clerk." Second, at the court's request, plaintiff identified the railroad clerk involved, who has filed an affidavit confirming that he received the letter on the date indicated, and gave it to plaintiff immediately thereafter. Plaintiff swears he received the letter "about or after July 13, 1978." If plaintiff's version of the facts is to be accepted, he filed this action within sixty days of receiving the notice of the Appeals Council's decision.

The government has failed to controvert plaintiff's allegations in any respect. Furthermore, plaintiff has presented a facially credible explanation for a later receipt than the regulations presume. Finally, plaintiff filed his complaint only five days late. While this fact would not excuse an untimely filing, however minimally late, it serves in the present circumstances to show that plaintiff was not sleeping on his rights, and makes his explanation somewhat more credible than it would have been if a much longer and less readily explained period had passed. Given the remedial nature of the statute, Haberman v. Finch, 418 F.2d 664 (2d Cir. 1969), and given the agency's authoritative construction making the sixty days period commence on receipt, the plaintiff here has made a "reasonable showing."

The government's motion to dismiss is denied, and the parties are hereby ordered to make such motions on the merits as may be proper within thirty days.

SO ORDERED.


Summaries of

Chiappa v. Califano

United States District Court, S.D. New York
Dec 3, 1979
480 F. Supp. 856 (S.D.N.Y. 1979)

holding that the plaintiff overcame the presumption of notice by presenting affirmative evidence that the notice was mailed to a house that the plaintiff sold and was no longer living in

Summary of this case from Ramirez v. Colvin

finding that the plaintiff overcame the presumption where the plaintiff had sold the house to which the notice was sent, the notice itself was marked with the date it was received, and the letter carrier who personally delivered the notice confirmed the plaintiff's assertion as to when the notice was received

Summary of this case from Velazquez v. Massanari

denying the government's motion to dismiss because plaintiff had made a reasonable showing to contradict the presumption of receipt within five days of the Appeals Council's notice of decision.

Summary of this case from Matsibekker v. Heckler

In Chiappa v. Califano, 480 F.Supp. 856, 857 (S.D.N.Y. 1979), the plaintiff had moved, and the notice of decision originally was mailed to his prior address before being forwarded to his new address.

Summary of this case from Bickram v. Commissioner of Social Security

rebutting presumption where Plaintiff showed he no longer lived at address notice mailed to

Summary of this case from Shine v. Comm'r of Soc. Sec.

rebutting presumption where plaintiff established he no longer lived at address to which notice was mailed

Summary of this case from Halstead v. Comm'r of Soc. Sec.

In Chiappa v. Califano, 480 F.Supp. 856, 857 (S.D.N.Y. 1979), the claimant rebutted the presumption by showing he had changed addresses at the time he filed his administrative appeal. Furthermore, the Chiappa claimant submitted an affidavit from a "railroad clerk" who had forwarded the Appeals Council notice to the claimant's new address more than a month after the notice date.

Summary of this case from Kesoglides v. Comm'r of Soc. Sec.

noting that the facts indicated that the plaintiff "was not sleeping on his rights"

Summary of this case from Velazquez v. Massanari

In Chiappa, plaintiff explained that he had temporarily moved and that the letter was forwarded to his new address as was indicated on the notice by the railroad clerk.

Summary of this case from Leslie v. Bowen
Case details for

Chiappa v. Califano

Case Details

Full title:Richard E. CHIAPPA, Plaintiff, v. Joseph E. CALIFANO, Secretary of Health…

Court:United States District Court, S.D. New York

Date published: Dec 3, 1979

Citations

480 F. Supp. 856 (S.D.N.Y. 1979)

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