Term: 2018
Docket: 17-1606
Smith v. Berryhill
- Pro
17-1606 SMITH V. BERRYHILL DECISION BELOW: 880 F.3d 813 ORDER OF 11/5/2018: DEEPAK GUPTA, ESQUIRE, OF WASHINGTON, D. C., IS INVITED TO BRIEF AND ARGUE THIS CASE, AS AMICUS CURIAE, IN SUPPORT OF THE JUDGMENT BELOW. CERT. GRANTED 11/2/2018 QUESTION PRESENTED: The Social Security Act provides for judicial review of administrative decisions rejecting benefits claims: "[a]ny individual, after any final decision of the Commissioner of Social Security made after a hearing to which he was a party," may obtain judicial review of that decision in federal court. 42 U.S.C. §405(g). Disability benefit claims are initially heard by an administrative law judge; adverse decisions may be appealed to the Appeals Council. Appeals Council decisions rejecting a claim on the merits are subject to judicial review. But the courts of appeals disagree about whether judicial review is available when the Appeals Council finally rejects a claim on the ground that the claimant's administrative appeal was not timely. The question presented is whether the Appeals Council's decision to reject a disability claim on the ground that the claimant's appeal was untimely is a "final decision" subject to judicial review under Section 405(g). LOWER COURT CASE NUMBER: 17-5809
The case of Smith v. Berryhill, 2018, involved a dispute over the Social Security Administration's (SSA) dismissal of Ricky Lee Smith's disability benefits claim. The SSA Appeals Council had dismissed his request for review as untimely without considering the merits of his case. Smith then sought judicial review in federal court under Section 405(g) of the Social Security Act, which allows individuals to obtain judicial review after any "final decision" made by the Commissioner following a hearing. However, lower courts ruled that they lacked jurisdiction because the Appeals Council’s dismissal did not constitute a final decision on account of it being procedural rather than substantive. When brought before Supreme Court, it held that when an applicant has appeared at and presented evidence in an administrative law judge hearing regarding their entitlement to benefits under Title II or XVI and later seeks appellate review within SSA but is denied due to timeliness issue by Appeals Council - such denial qualifies as 'final decision' made after hearing thus allowing federal courts jurisdiction for further reviewing.
In the dissenting opinion for Smith v. Berryhill, Justice Sotomayor argued that the majority's decision expanded judicial review of Social Security Administration (SSA) decisions beyond what Congress intended. She contended that under the law, federal courts only have jurisdiction to review "final decisions" made after a hearing. In this case, she believed there was no final decision because an Appeals Council dismissed Smith’s request for review on procedural grounds rather than on its merits. Therefore, according to her interpretation of the statute and precedent cases like Califano v Sanders (1977), such dismissal should not be subject to judicial scrutiny as it is not a 'final decision'. By allowing court reviews in these circumstances, she warned that floodgates could open for challenges against any SSA procedural ruling which would burden both claimants and courts with unnecessary litigation.
