Carr v. Saul
United States Supreme Court
141 S. Ct. 1352 (2021)
- Written by Eric Miller, JD
Facts
Willie Earl Carl and others (collectively, the claimants) (plaintiffs) were unsuccessful applicants for disability benefits in unrelated proceedings before administrative-law judges (ALJs) for the Social Security Administration (SSA) (defendant). The ALJs had been appointed by SSA staff. Later, the Supreme Court held that ALJs for the Securities and Exchange Commission (SEC) were unconstitutionally appointed because they had been appointed by SEC staff rather than by the head of the department as required by the Appointments Clause. In light of this decision, the SSA issued a ruling stating that timely Appointments Clause objections would merit fresh review by a constitutionally appointed ALJ. Although the claimants’ cases had already concluded by this point, the claimants sought new hearings before new ALJs. The SSA commissioner conceded that no statute or regulation specifically required exhaustion of issues within SSA-based administrative proceedings. Nevertheless, courts of appeals for the Eighth and Tenth Circuits held that judicial review of the Appointments Clause claims was not available because the claimants had failed to raise their objections during their original SSA proceedings. The consolidated cases came before the Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Sotomayor, J.)
Concurrence (Breyer, J.)
Concurrence (Thomas, J.)
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