Smithv.Berryhill
Ricky Lee Smith pursued Social Security disability benefits through an administrative hearing on the merits. He sought review by the Social Security Administration’s Appeals Council, but the Council dismissed the request as untimely. The district court held that it lacked jurisdiction to review that dismissal, and the Sixth Circuit affirmed. The Supreme Court reversed and remanded. It held that when a claimant has received an administrative law judge’s hearing on the merits, an Appeals Council dismissal on timeliness grounds is a final decision made after a hearing under the judicial-review provision of the Social Security Act. The statute’s use of any final decision is expansive, and the Appeals Council dismissal is the agency’s final stage of review. On remand, judicial review ordinarily should address the procedural basis for the dismissal before the agency reaches any remaining merits questions. The decision distinguishes a late request for review after a merits hearing from a request to reopen an earlier denial and defines the reviewable finality of agency procedure.
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