In the case of Heckler, Secretary of Health and Human Services v. Ringer et al., 1983, four Medicare patients sought declaratory and injunctive relief to challenge a policy implemented by the Secretary of Health and Human Services that denied Medicare coverage for a specific surgical procedure unless it was deemed reasonable and necessary for treatment. The Supreme Court ruled in favor of the defendant, stating that under Section 405(g) of Social Security Act, judicial review could only be sought after all administrative remedies were exhausted. The court also held that plaintiffs' claim did not constitute an exception to this rule as they had failed to establish any constitutional issues or demonstrate irreparable harm if required to exhaust their administrative remedies first. Therefore, federal courts lacked jurisdiction over such claims until after final decision from agency proceedings.

In the dissenting opinion for Heckler v. Ringer, it was argued that the majority's decision effectively denied claimants of Medicare Part A benefits their right to judicial review. The dissenting justices believed that this case should not have been dismissed on jurisdictional grounds because the Social Security Act does not preclude federal courts from hearing constitutional claims or claims arising under federal law. They also disagreed with the majority’s interpretation of 42 U.S.C §405(g), arguing that it is a waiver of sovereign immunity and a grant of subject-matter jurisdiction to federal courts over any action arising under Medicare laws. Furthermore, they contended that by requiring claimants to exhaust administrative remedies before seeking judicial review - even when such exhaustion would be futile - places an undue burden on individuals who may need immediate access to medical treatment but cannot afford it without Medicare coverage.