John Lee Perkins v. Commissioner of Social Security Administration

Summary

The United States District Court for the Eastern District of Kentucky denied John Lee Perkins’s motion for reconsideration under Federal Rules of Civil Procedure 59(e) and 60(b). The court held that it had not improperly applied Chevron deference after Loper Bright and had independently interpreted 42 U.S.C. § 405(u). It also held that the administrative law judge properly excluded 2016 anxiety-treatment records because they did not relate to the period relevant to the fraud-related benefits redetermination.

Holdings

1. The court did not clearly err because it independently interpreted § 405(u) and concluded that a fraud-related redetermination is temporally linked to the original application and favorable determination, rather than extending to impairments arising afterward.
2. The ALJ properly excluded the 2016 anxiety-treatment records because Plaintiff did not show that anxiety existed during or was linked to the original period at issue; therefore, the court did not clearly err in affirming the Commissioner's decision.
3. Plaintiff failed to establish clear error or another basis for relief under Rule 59(e), and the court denied the reconsideration motion.

Questions Presented

1. Whether the court clearly erred by allegedly applying Chevron deference to Social Security Ruling 22-1p after Loper Bright Enterprises v. Raimondo.
2. Whether the court clearly erred by affirming the ALJ's refusal to consider 2016 anxiety-treatment records in the § 405(u) redetermination.
3. Whether Plaintiff was entitled to relief from the prior judgment under Federal Rule of Civil Procedure 59(e) or Rule 60(b)(1).

Disposition

other