Ramsey v. Commissioner of Social Security
United States Court of Appeals for the Sixth Circuit
973 F.3d 537 (2020)
- Written by Nicole Gray , JD
Facts
Ramsey (plaintiff) was one of several Social Security benefits claimants (plaintiffs) who were denied benefits following hearings before administrative-law judges (ALJ) who had neither been appointed by the president, a court, nor the commissioner of the Social Security Administration (defendant). Ramsey (plaintiff) and the other claimants each sought judicial review of the commissioner’s denials, raising Appointments Clause challenges for the first time. The claimant’s suits followed a Supreme Court decision wherein the Court found that the Security and Exchange Commission’s ALJs had not been appointed as constitutionally required by the Appointments Clause and remanded the case for rehearing before a different ALJ. In this case, the commissioner conceded that there was no statutory or regulatory exhaustion requirement governing Social Security proceedings. However, the commissioner argued that Ramsey and the other claimants had forfeited review of the issue by failing to raise it at the administrative level. District courts affirmed the denials. The cases were consolidated on appeal.
Rule of Law
Issue
Holding and Reasoning (White, J.)
Dissent (Siler, J.)
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