In Smith v. O’Malley, the U.S. District Court for the Eastern District of California denied a motion by the Social Security Administration (SSA) to amend the judgment following a prior order remanding the disability case of Jason Brian Smith. The court rejected the SSA’s attempt to revise its analysis of the administrative law judge’s (ALJ) treatment of medical opinion evidence.
Background and Procedural History
Jason Smith filed a claim for Social Security Disability Insurance (SSDI) benefits. After his claim was denied, he brought a civil action under 42 U.S.C. § 405(g) seeking judicial review. In a September 14, 2023 order, the court granted Smith’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded the case for further administrative proceedings.
At issue was the ALJ’s evaluation of a medical opinion provided by Physician Assistant (PA) Lacey Townsend, one of Smith’s own treating sources. The ALJ deemed the opinion "unpersuasive" but failed to provide an adequate explanation for that conclusion.
The SSA filed a motion under Federal Rule of Civil Procedure 59(e) seeking to amend the judgment, arguing that the court had failed to properly evaluate the reasons the ALJ cited in rejecting Townsend’s opinion.
Court’s Analysis and Denial of Motion to Amend
The court reiterated that altering a judgment under Rule 59(e) is an extraordinary remedy, only warranted for manifest legal or factual error, newly discovered evidence, or an intervening change in controlling law. The court emphasized that Rule 59(e) cannot be used to relitigate matters already resolved or to raise arguments that could have been made earlier.
In rejecting the SSA’s motion, the court highlighted that the ALJ’s original opinion failed to meet the standards for articulating why a medical opinion is unpersuasive. Specifically:
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The ALJ provided no detailed discussion of PA Townsend’s supportability or consistency.
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The ALJ’s references to evidence "above" and "below" in the opinion were vague and conclusory.
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The ALJ did not cite to specific findings in the record or clearly link medical evidence to the rejection of the opinion.
The court further noted that it had relied on Ninth Circuit precedent, including Woods v. Kijakazi and Kitchen v. Kijakazi, both of which require ALJs to articulate their reasoning with specificity and to identify supporting evidence.
Finding that the SSA’s motion merely sought to reargue issues already addressed in the original decision, the court denied the motion to amend.
Legal Support for Social Security Disability Appeals
Claimants denied SSDI benefits due to improper handling of medical opinions may challenge such decisions in federal court. Our team at Whitcomb, Selinsky, PC helps clients prepare strong appeals, enforce SSA adjudication standards, and seek remands or reversals where administrative errors have occurred.
Joe Whitcomb
