Canales v. Sullivan
United States Court of Appeals for the Second Circuit
936 F.2d 755 (1991)
- Written by Samantha Arena, JD
Facts
In August 1986, Dolores Canales (plaintiff) applied for Supplemental Security Income (SSI), claiming disability stemming from various conditions, including major depressive disorder. Canales’s application was denied. Canales appealed. An administrative-law judge (ALJ) concluded that Canales was not disabled. The decision letter notified Canales that she had a 60-day window to request review of the ALJ’s decision. Caneles appealed. The appeals council affirmed the ALJ’s decision. The decision letter again informed Canales of her right to obtain review by the district court by filing a complaint within 60 days of receipt. When Canales received the letter, Canales was still undergoing treatment for her psychiatric issues. Due to her limited English comprehension, Canales’s 12-year-old daughter read her the letter. Learning that the denial was upheld caused Canales to feel further distressed, and Canales later asserted that she had not understood her right to appeal. Months later, an advocacy attorney told Canales that she could appeal but that Canales missed the deadline. Forty days after the 60-day expiration period, Canales filed a complaint in the district court. Louis Sullivan (defendant), Secretary of the US Department of Health and Human Services, sought dismissal of the complaint for failure to comply with the statute of limitations. The motion was granted. Canales then requested relief from the judgment under § 60(b) of the Federal Rules of Civil Procedure. The district court granted the motion but declined to reach the merits of Canales’s SSI claim because equitable tolling was unjustified.
Rule of Law
Issue
Holding and Reasoning (Lumbard, J.)
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