Udd v. Massanari

In March 1976, the Social Security Administration determined that Kris Udd (plaintiff) had been disabled since May 3, 1974, due to visual and auditory hallucinations, loss of control of his arms and legs, and schizophrenia. Udd received benefits until October 31, 1976, when his benefits were terminated for unknown reasons. At the time, Udd did not have an attorney or a legal guardian and did not request review of the termination decision. In 1994, Udd reapplied for benefits and was found to have been continuously disabled since November 1, 1976. However, due to an administrative rule, Udd could only receive retroactive benefits for the 12 months preceding his 1994 application. Udd requested a hearing, urging that his 1976 termination decision be reopened because he lacked the mental capacity, then, to understand the procedure for timely appealing. Udd presented medical evidence to an administrative-law judge (ALJ), who found that Udd did not lack the mental capacity to understand the review procedures in 1976 because although Udd’s mental impairment prevented him from working, he was not incapacitated as evidenced by his ability to live alone and maintain relationships, as well as some babysitting he performed in December 1976. Accordingly, the ALJ did not excuse Udd’s failure to appeal or vacate the 1976 termination decision. The decision became the final decision of the Commissioner of the Social Security Administration, Larry Massanari (defendant). Udd requested judicial review from a United States district court, which affirmed the ALJ’s decision. Udd appealed.