Jeanett M. v. Kijakazi
- Jacquelyn Corley
- 3:21-cv-00587
- U.S. District Court · Northern District of California
- 2
In Jeanett M. v. Kijakazi, Judge Corley denied the agency’s request to change a prior summary-judgment ruling because no clear error was shown.
The defendant’s request to change the prior judgment was denied; the opinion does not identify any additional change to the judgment.
What happened
In Jeanett M. v. Kijakazi, the court had previously granted summary judgment to Jeanett M. and entered judgment. The defendant then asked the court to change that judgment under Federal Rule of Civil Procedure 59(e), challenging one sentence about what an administrative law judge must explain when evaluating medical opinions.
The court found no clear error. It explained that the agency must explain how it considered the supportability and consistency of medical opinions, but may explain—and is not required to explain—the other listed factors, including the relationship with the claimant, specialization, and other factors. The defendant’s preference for different wording did not show a clear legal or factual mistake.
Judge Jacquelyn Corley denied the defendant’s motion to alter or amend the judgment. The order disposed of Docket No. 25.
The detailed version
- Jeanett M. v. Kijakazi · No. 3:21-cv-00587
- Jacquelyn Corley
- June 23, 2022
Background
The court had granted summary judgment to Jeanett M. on April 27, 2022, and entered judgment on May 2, 2022. The defendant filed a motion under Federal Rule of Civil Procedure 59(e) asking the court to alter or amend the judgment. The motion challenged a sentence in the earlier summary-judgment order concerning the explanation required from an administrative law judge when evaluating medical-opinion evidence.
The challenged language
The earlier order stated that the administrative law judge must explain how the agency considered the supportability and consistency factors, may explain how it considered the relationship factors, and is not required to explain the other factors. The defendant argued that this wording should be changed.
Court’s reasoning
The court explained that the governing regulation requires the agency to explain how it considered supportability and consistency. The regulation also states that the agency may, but is not required to, explain how it considered the relationship with the claimant, specialization, and other factors.
The court rejected the argument that its use of “may” and “is not required to” created a legally significant distinction amounting to clear error. It also held that the defendant’s preference for different wording, or for language quoting the regulation more directly, did not establish a clear legal or factual mistake. The court therefore declined to use the extraordinary remedy provided by Rule 59(e).
Disposition
Judge Jacquelyn Corley denied the defendant’s motion to alter or amend the judgment. The order states that it disposes of Docket No. 25.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.