Hayward v. Social Security Administration, 5:17-cv-00691

Plaintiff LaTonya Hayward, on behalf of her minor child, appealed the denial of Social Security disability benefits by the ALJ and Commissioner.
ALJ Charles Lindsay held a hearing, issued a written decision denying benefits, and the Appeals Council denied review.
Plaintiff filed a bare-bones pro se complaint in federal court but did not identify specific errors in the administrative decision.
The court’s Scheduling Order required Plaintiff to file a memorandum brief within 60 days identifying specific alleged errors and warned that failure could lead to dismissal.
Plaintiff missed the initial and extended briefing deadlines and did not file any brief; the court found it could not perform meaningful review without specified errors.
The magistrate judge recommended dismissal without prejudice for failure to prosecute and provided statutory notice about objections and appeal consequences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal can proceed without a merits brief	Hayward filed a general complaint but raised no specific errors.	Commissioner argued the record was complete and plaintiff failed to prosecute by not briefing issues.	Court: Appeal dismissed without prejudice for failure to prosecute due to no brief identifying errors.
Whether the court can sua sponte dismiss for failure to prosecute	Implicit: plaintiff did not oppose dismissal (no filings).	Cites Rule 41(b) and court’s inherent docket control powers permitting dismissal.	Court: Dismissal authorized under Rule 41(b) and inherent powers; sua sponte dismissal warranted.
Whether general allegation of lack of substantial evidence suffices to invoke review	Hayward’s general allegation is insufficient per scheduling order.	Commissioner: specific errors required to permit meaningful deferential review.	Court: General allegation insufficient; must identify specific errors.
Whether plaintiff was given adequate notice/opportunity before dismissal	Plaintiff received Scheduling Order, extension, and warning of dismissal; no response.	Commissioner: procedural notices satisfied; dismissal appropriate.	Court: Notices were adequate; dismissal recommended, with instructions on objections and appeal.

Masterson v. Barnhart, 309 F.3d 267 (5th Cir. 2002) (describing federal court review of Social Security disability decisions and insufficiency of general allegations)
Rogers v. Kroger Co., 669 F.2d 317 (5th Cir. 1983) (district court may dismiss for failure to prosecute under inherent powers)
Link v. Wabash R.R. Co., 370 U.S. 626 (1962) (a court may dismiss an action sua sponte for failure to prosecute)
Douglass v. U.S.A.A., 79 F.3d 1415 (5th Cir. 1996) (failure to object to a magistrate judge’s recommendation bars appellate challenge except for plain error)