Carr v. Saul
Issues
Must claimants seeking Social Security benefits administratively exhaust their constitutional claims before seeking judicial review?
This case asks the Supreme Court to determine whether Social Security claimants must exhaust constitutional legal issues before an intra-agency adjudicative body—such as a Social Security Administration administrative law judge or appeals board—before seeking review of that issue in court. Petitioner Willie Carr argues that a requirement of issue exhaustion is inappropriate for his Appointments Clause challenge because no statute mandates issue exhaustion and a judicially-crafted requirement would break with historical precedent. Respondent Andrew Saul, Commissioner of the Social Security Administration, counters that a general rule of judicial economy is applicable here, and that all issues can and must be exhausted before an administrative body before a claimant can seek review. This case has important implications for the procedural ease of new challenges to prior adverse benefits rulings for Social Security claimants, as well as the dockets of reviewing courts.
Questions as Framed for the Court by the Parties
Whether a claimant seeking disability benefits under the Social Security Act forfeits an appointments-clause challenge to the appointment of an administrative law judge by failing to present that challenge during administrative proceedings.
In 2014, Willie Earl Carr attempted to claim disability benefits from the Social Security Administration (“SSA”). Carr v. Comm’r, SSA at 5. In 2017, administrative law judges (“ALJs”) denied the claims. Id. Carr then sued in the Northern District of Oklahoma.
Edited by
Additional Resources
- Kimberly Strawbridge Robinson, Justices Trade Blockbusters for “Meat and Potatoes” in 2021, Bloomberg Law (Jan. 4, 2021).
- Matthew Borges, Supreme Court to Hear Appointments Clause Challenge to Administrative Judges, Jurist (Nov. 10, 2020).