Carr v. Saul
Overview
Overview
The Supreme Court held that Social Security claimants are not required to exhaust administrative remedies before a federal court can hear their constitutional challenges to the agency's adjudicative process. The ruling lowered the barrier for disability claimants challenging the ALJ appointment process.
The Facts
Facts
Carr and other claimants challenged their Social Security disability denials on the ground that the ALJs who heard their cases were unconstitutionally appointed. A structural defect they had not raised during administrative proceedings. The government argued they forfeited the claim by failing to raise it before the agency.
The Issue
Issue
Whether a Social Security claimant must raise an Appointments Clause challenge to an ALJ's appointment before the agency to preserve that challenge for judicial review.
The Rules
Rule
Issue exhaustion before an agency is not required when the agency's adjudicative structure makes raising a constitutional challenge futile. SSA ALJs cannot dismiss cases or grant relief based on Appointments Clause defects. Requiring claimants to raise a challenge the agency cannot resolve would be a pointless exercise that serves no exhaustion purpose.
The Application
Analysis
The Court applied the futility doctrine to these claimants' Appointments Clause challenge, reasoning that because ALJs lack authority to dismiss cases or grant relief on constitutional grounds, requiring exhaustion before the agency would serve no purpose. The structural defect in the ALJs' appointment was not a matter the SSA could cure through its internal review process. It required judicial resolution. Accordingly, the exhaustion requirement, which ordinarily gives an agency an opportunity to correct errors or develop a factual record, would be a meaningless formality when the constitutional challenge involves the very authority of the decision-maker.
The Conclusion
Conclusion
Court held 7-2 that exhaustion was not required for Appointments Clause challenges in this context. Dissenters: Thomas, Alito.
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