Cooley v. Social Security Administration ( 2022 )

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA BRYAN M. COOLEY CIVIL ACTION VERSUS NO: 21-840 SOCIAL SECURITY SECTION: T ADMINISTRATION ORDER Before the Court is Bryan Cooley’s Motion for Reconsideration.1 The Social Security Administration filed a response and opposed Mr. Cooley’s original objections.2 For the following reasons, the motion is DENIED. BACKGROUND Earlier this year, this Court overruled Bryan Cooley’s objections and adopted the Magistrate Judge’s Report and Recommendations.3 This Court reasoned that, per federal case law, Mr. Cooley failed to “allege an inability” to perform his work and “specify a nexus” between his alleged mental limitations and an inability to work.4 Now, Mr. Cooley asks this Court to reconsider its decision. Generally, Mr. Cooley contends the Magistrate Judge’s report, and consequently this Court’s decision, was “unequivocally wrong” for two reasons.5 First, by holding that an analysis 1 R. Doc. 26. 2 R. Docs. 23, 29. 3 R. Docs. 19, 24. 4 R. Doc. 24 at 2. 5 R. Doc. 26-1 at 1-2. of the composite job issue was “unnecessary,” the Magistrate Judge’s report was “legally incorrect” and requires correction.6 Second, Mr. Cooley maintains that, by filing an application for disability, he necessarily “alleged an inability” to work.7 The Commissioner of the Social Security Administration filed a short response and addressed Mr. Cooley’s arguments in her original opposition to his objections.8 The Commissioner contends that, while Mr. Cooley’s legal analysis holds merit, he overlooks the fact that “the ALJ never found that [Mr. Cooley’s] warehouse manager job was a composite job.”9 Additionally, the Commissioner maintains that Mr. Cooley’s contentions, contrary to the applicable legal requirements, “are repeats of those arguments raised in [his] Motion for Summary Judgment.”10 LAW & ANALYSIS Under Federal Rule of Civil Procedure 59, a party may “call[] into question the correctness of a judgment” or order, and ask a court to reconsider it.11 Ultimately, such motions “serve[] the narrow purpose of allowing a party to correct manifest errors of law or fact or to present newly discovered evidence.”12 However, reconsideration of an order is a “extraordinary remedy,” and it “is not the proper vehicle for rehashing evidence, legal theories, or arguments that could have been 6 Id. at 2. 7 Id. 8 R. Doc. 23. 9 Id. at 2. 10 R. Doc. 28-2 at 1. 11 Templet v. HydroChem Inc., 367 F.3d 473, 478 (5th Cir. 2004) (quoting In re Transtexas Gas Corp., 303 F.3d 571, 581 (5th Cir. 2002)). 12 Id. at 479 (quoting Waltman v. Int’l Paper Co., 875 F. 2d 468, 473 (5th Cir. 1989). offered or raised before.”13 Importantly, district courts have wide discretion in granting or denying motions for reconsideration.14 Here, Mr. Cooley fails to point this Court to some mistake of fact or law, or new evidence.15 Mr. Cooley contends it “is beyond any dispute whatsoever that if a composite job is present here then” the Administrative Law Judge’s (“ALJ”) findings are flawed.16 However, his argument fails for two reasons. First, it is the same point Mr. Cooley raised in his objections to the Magistrate Judge’s Report & Recommendation. In other words, he is simply “rehash[ing]…legal theories, or arguments” already known to this Court. Second, Mr. Cooley’s argument is without merit. As noted in this Court’s previous order, Mr. Cooley cannot “specify a nexus between his alleged [] limitations and his ability to work.”17 As noted by the Magistrate Judge, it is “unnecessary” to explore the nature of the Plaintiff’s job because the “Plaintiff does not allege an inability” to perform his past duties as a warehouse manager. Ultimately, the Plaintiff “failed to specify a nexus between his alleged mental health limitations and his inability to work.” Regardless, the ALJ “properly concluded that [the Plaintiff] can indeed perform light work” despite his unsupported “mental limitations” claims.18 That reasoning remains sound for two reasons. First, even if this Court erred in finding Mr. Cooley did not adequately claim a disability, the ALJ validly found that he can still perform his past relevant work.19 Therefore, his claim for disability is defeated regardless of the grounds on 13 Id. at 478-79. 14 Id. at 479. 15 R. Doc. 26-1. 16 Id. at 1. 17 R. Doc. 24 at 1. 18 Id. at 1-2 (citations omitted). 19 R. Doc. 19 at 2. which this Court’s decision rests on.”° Second, the ALJ never found Mr. Cooley’s claim involved a “composite job.” Consequently, the various alleged legal missteps fall away, leaving only the fact that Mr. Cooley can still perform his past relevant work. Accordingly, the motion is DENIED. CONCLUSION For the foregoing reasons, IT IS ORDERED that the motion is DENIED. New Orleans, Louisiana, this 18th day of August, 2022. Hon.Greg Gerard Guidry United States District Judge 29 “Tn Henderson v. Saul, the claimant had varied job tasks that fell under multiple DOT codes, and there was no need to resolve whether her PRW was a ‘composite job,’ as the claimant could perform her past relevant work based on her recent performance of it and her failure to allege otherwise. See Civ. A. No. 20-2045, 2021 WL 3508495, at *5, 8 (E.D. La. July 13, 2021). As discussed below, Plaintiff has failed to specify a nexus between his alleged mental health limitations and his inability to work, and, moreover, his proffered explanations for leaving the workforce were inconsistent.” Id. at 7.