Crawford v. Commissioner of Social Security, 3:21-cv-05178

Plaintiff Patricia Irene Crawford appealed the denial of Social Security disability benefits; the parties agreed the ALJ erred in evaluating her claim.
On January 11, 2022 the Court remanded the case to the Social Security Administration for further administrative proceedings rather than awarding benefits and entered judgment for Plaintiff.
Plaintiff filed a timely motion for reconsideration under Federal Rule of Civil Procedure 59(e), arguing the Court committed "manifest error" by declining to award benefits.
The Rule 59(e) standard (as applied) requires newly discovered evidence, clear error, or an intervening change in controlling law to justify altering a judgment.
The Court found Plaintiff only reiterated and expanded prior arguments, presented no new evidence, and did not show clear error or a change in law, and therefore denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 59(e) reconsideration is warranted	Court committed manifest error; judgment should be altered and benefits awarded	Plaintiff reasserts prior claims; no new evidence, clear error, or intervening law change	Denied — Plaintiff failed to meet Rule 59(e) standard
Whether remand should be for immediate benefits or further proceedings	Record supports award of benefits instead of further proceedings	Record contains conflicts; further administrative factfinding is useful	Court previously remanded for further proceedings, not for an award of benefits

Carroll v. Nakatani, 342 F.3d 934 (9th Cir. 2003) (Rule 59(e) relief is extraordinary; grounds limited)
Kona Enters., Inc. v. Estate of Bishop, 229 F.3d 877 (9th Cir. 2000) (motions to alter judgment require new evidence, clear error, or intervening law change)
Shapiro ex rel. Shapiro v. Paradise Valley Unified Sch. Dist. No. 69, 374 F.3d 857 (9th Cir. 2004) (local reconsideration motions are treated as Rule 59(e) motions)