Clements v. Commissioner: Eleventh Circuit Re-Affirms Strict Standards for Rule 60(b) Relief and Sentence-Six Remands in Social Security Disability Cases

1. Introduction

The unpublished decision in Louis Matthew Clements v. Commissioner of Social Security, No. 23-12520 (11th Cir. July 9, 2025) concerns a Social Security disability claimant’s attempt to reopen an adverse judgment by invoking Federal Rule of Civil Procedure 60(b). After losing at the agency level, in the District Court, and in an earlier Eleventh Circuit appeal, Mr. Clements filed a Rule 60(b) motion alleging “mistake,” “newly discovered evidence,” and “fraud.” The District Court denied the motion, and Mr. Clements appealed again. The Eleventh Circuit—via a non-argument, per curiam opinion—affirmed, thereby cementing a clear message: Rule 60(b) is an extraordinary remedy, and neither pro se status nor generalized allegations can lower its demanding bar, particularly in the Social Security context.

2. Summary of the Judgment

Holding: The District Court did not abuse its discretion in denying Mr. Clements’s Rule 60(b)(1)–(3) motion; judgment is affirmed.
Key Findings:
- Alleged errors in medical diagnosis dates, even if true, were not shown to affect the outcome (Rule 60(b)(1)).
- “New” medical documents were either pre-existing, cumulative, immaterial, or obtainable with due diligence; none could support reopening (Rule 60(b)(2)).
- Speculative claims of systemic fraud, unsupported by clear and convincing evidence, cannot warrant relief (Rule 60(b)(3)).
- To the extent the motion could be construed as a request for a sentence-six remand under 42 U.S.C. § 405(g), Clements failed to satisfy the same stringent materiality and due-diligence standards.
Standard of Review Applied: Abuse of discretion.
Result: Appeal dismissed; original denial of benefits stands.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

Edward Lewis Tobinick, MD v. Novella, 848 F.3d 935 (11th Cir. 2017) – articulates the abuse-of-discretion standard for Rule 60(b) motions.
Aycock v. R.J. Reynolds Tobacco Co., 769 F.3d 1063 (11th Cir. 2014) – outlines when a district court abuses its discretion (incorrect legal standard, improper procedure, clearly erroneous findings).
Cavaliere v. Allstate Ins. Co., 996 F.2d 1111 (11th Cir. 1993) – limits appellate review to the 60(b) ruling, not the underlying merits.
Maradiaga v. United States, 679 F.3d 1286 (11th Cir. 2012) – “justification so compelling” language underscoring Rule 60(b)’s high threshold.
Application of Consorcio Ecuatoriano de Telecomunicaciones S.A. v. JAS Forwarding (USA), Inc., 747 F.3d 1262 (11th Cir. 2014) – five-part test for newly discovered evidence.
Toole v. Baxter Healthcare Corp., 235 F.3d 1307 (11th Cir. 2000) – Rule 60(b)(2) is “extraordinary” and must be “strictly met.”
Waddell v. Hendry County Sheriff’s Office, 329 F.3d 1300 (11th Cir. 2003) – due-diligence requirement under Rule 60(b)(2); clear-and-convincing evidence standard for 60(b)(3) fraud.
Caulder v. Bowen, 791 F.2d 872 (11th Cir. 1986) – definition of “material” evidence in Social Security remand context.
Ingram v. Commissioner of Social Security, 496 F.3d 1253 (11th Cir. 2007) – sentence-six remand parallels Rule 60(b)(2) criteria.
Erickson v. Pardus, 551 U.S. 89 (2007) – generous construction of pro se pleadings, but not unlimited indulgence.

Collectively, these precedents frame the stringent requirements for post-judgment relief and clarify that Rule 60(b) cannot be used to relitigate issues or circumvent procedural constraints.

3.2 Court’s Legal Reasoning

Mistake (Rule 60(b)(1)). Even assuming error in diagnosis dates, Mr. Clements failed to articulate materiality—the ALJ had already accepted the existence of the conditions. Absent a nexus between the asserted mistake and the adverse disability finding, relief is unavailable.
New Evidence (Rule 60(b)(2)).
- Pre-existing doctor-visit summaries: cumulative and immaterial.
- Physician questionnaire: obtainable earlier; fails due-diligence prong; duplicative of accepted diagnoses.
- 2023 progress note: post-decision deterioration may support a new benefits application, but cannot reopen the closed record.
- Therefore, none satisfies the JAS Forwarding five-factor test.
Fraud (Rule 60(b)(3)). Systemic criticism gleaned from a newspaper article does not amount to clear and convincing evidence that the Commissioner or ALJ engaged in fraud in this specific case, nor did it prevent Mr. Clements from fully litigating.
Sentence-Six Remand (42 U.S.C. § 405(g)). The panel expressly notes that even if construed as such a request, the same materiality and due-diligence shortcomings doom relief.
Pro Se Considerations. Citing Bilal v. Geo Care, LLC, the Court refuses to become “de facto counsel” for a pro se litigant; liberal construction does not obviate substantive burdens.

3.3 Potential Impact on Future Litigation

Reiterates that Rule 60(b) is not a second appeal; litigants must show a decisive connection between alleged error and judgment.
Clarifies that new medical evidence relating to Social Security disability after a final agency decision is best pursued by filing a new claim, not by Rule 60(b).
Signals to the bar that generic accusations of systemic agency flaws will not meet the clear-and-convincing standard for fraud.
Provides District Courts within the Eleventh Circuit a concise, citation-rich template for denying meritless 60(b) motions in benefits cases, thereby promoting docket efficiency.
Strengthens deference to ALJ findings when the claimant cannot pinpoint how alleged errors undercut the residual functional capacity analysis.

4. Complex Concepts Simplified

Rule 60(b): A procedural rule allowing a federal court to reopen a final judgment for specified exceptional reasons: (1) mistake, (2) newly discovered evidence, (3) fraud, (4) void judgment, (5) satisfaction, or (6) any other extraordinary circumstance.
Sentence-Six Remand (42 U.S.C. § 405(g)): Unique to Social Security litigation; authorizes a federal court to send a case back to the agency after judgment if the claimant later obtains new, material evidence that could not have been presented earlier.
Materiality: Evidence is “material” if there is a reasonable possibility it would change the outcome; merely confirming already-established facts is insufficient.
Due Diligence: A party must show they could not have discovered and presented the evidence with reasonable effort before judgment.
Clear and Convincing Evidence: A level of proof requiring a high degree of certainty—more than a preponderance but less than beyond a reasonable doubt.
Abuse of Discretion Standard: An appellate court will reverse only if the lower court applied the wrong legal standard, made a clear error of judgment, or relied on clearly erroneous facts.

5. Conclusion

The Eleventh Circuit’s decision in Clements v. Commissioner reinforces the formidable obstacles litigants face when attempting to reopen Social Security judgments under Rule 60(b) or § 405(g) sentence six. The panel meticulously applied precedent to confirm that:

Materiality and outcome-altering impact are essential.
Evidence obtainable with reasonable diligence before judgment will not qualify as “newly discovered.”
Pro se status offers procedural leeway, not substantive shortcuts.
Broad allegations of systemic fraud, unsupported by case-specific proof, are insufficient.

Going forward, the decision serves as a cautionary guide: parties must marshal compelling, case-specific evidence and a concrete causal link to the judgment to succeed under Rule 60(b). In the Social Security arena, deteriorating conditions or additional diagnoses ordinarily call for a fresh benefits application, not a collateral attack on a closed record. The ruling thereby enhances finality, preserves judicial resources, and clarifies the strict limits of post-judgment relief in disability litigation.