The U.S. Supreme Court case Carr v. Saul, Commissioner of Social Security in 2020 revolved around the issue of whether claimants seeking disability benefits from the Social Security Administration (SSA) must raise their Appointments Clause challenges during administrative proceedings to preserve those issues for judicial review. The Appointments Clause refers to a provision in the U.S. Constitution that regulates the appointment and confirmation of certain federal officials by establishing them as principal officers who must be appointed by the President with Senate approval. In this case, six individuals had been denied social security benefits based on hearings conducted by SSA's Administrative Law Judges (ALJs). However, they argued that these ALJs were not properly appointed according to constitutional standards - an argument they did not initially bring up during their respective hearings. The Supreme Court ruled in favor of these claimants stating that it was unreasonable to expect them to have raised such a complex constitutional issue at agency-level proceedings before ALJs whose appointments were later deemed unconstitutional themselves. Therefore, failure to present an Appointments Clause challenge during administrative proceedings does not prevent raising this issue later in court.

In the dissenting opinion for Carr v. Saul, Justice Sotomayor argued that the majority's decision to allow claimants to bypass administrative review of their Appointments Clause challenges undermines Congress’s design for an efficient and centralized system of administrative review. She pointed out that this ruling could potentially flood federal courts with claims prematurely challenging Social Security Administration (SSA) proceedings before they are complete, which would disrupt SSA operations and delay benefits for those who need them most. Furthermore, she emphasized that there was no constitutional right at stake in these cases because all parties agreed that any error in appointing Administrative Law Judges (ALJs) was harmless since a validly-appointed officer later reviewed their decisions. Therefore, according to her view, it is unnecessary and counterproductive to permit such procedural shortcuts.