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Carrv.Saul

CourtSupreme Court of the United States
Docket No.19-1442
DecidedApril 22, 2021
Reporter593 U.S. 83
JudgesSupreme Court of the United States
Tags
CivilAdministrative LawConstitutional LawDue ProcessAppellate ProcedureFirst ImpressionReversalRemand
Case Summary

Six Social Security claimants challenged benefit denials after learning that the administrative law judges who decided their cases had been appointed in violation of the Constitution’s Appointments Clause. The Eighth and Tenth Circuits held that the claimants forfeited those challenges by failing to raise them during their agency proceedings. The Supreme Court held that the courts of appeals erred in imposing a judicially created issue-exhaustion requirement. Social Security proceedings are inquisitorial and nonadversarial, and the agency’s ALJs lacked both the technical role and the authority to provide relief on a structural constitutional challenge to their own appointments. Requiring claimants to present an issue to adjudicators who could not remedy it would also be futile. The Court rejected the Commissioner’s argument that the objections were untimely, distinguishing cases arising in genuinely adversarial systems with statutory exhaustion rules. It reversed both judgments and remanded for further proceedings. Justices Thomas and Breyer separately concurred in part and in the judgment.

Opinion

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