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Carr v. Saul

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This is a U.S. Supreme Court that concerns whether claimants who were denied Social Security disability benefits by the Social Security Administration (SSA) lose the opportunity to challenge the appointment of SSA administrative law judges (ALJs) in if they cannot present appointment clause challenges during proceedings for agency. The Supreme Court of the United States plans to hear the case in the October 2020-2021 term. The case came on a writ of certiorari to the United States Court of Appeals for the Tenth Circuit. It is also consolidates with the Davis v. Saul case.

Highlights

The case consists of Willie Carr was denied Social Security disability benefits and lost his appeals before the Social Security Administration (SSA). The U.S. Supreme Court decided Lucia v. SEC, while his appeal in federal court was pending, in which the court held that SEC ALJs were appointed improperly. Carr added an argument to his appeal in court that the SSA ALJ who decided benefits case was appointed improperly. A district court ruled in Carr’s favor, but the district court was reversed by the 10 circuit. The 10th Circuit argued that Carr had to have made his Appointments Clause challenge during proceedings at the SSA and could not raise the issue for the initial instance at the federal court.

The Issue

The issue is where “Whether claimants seeking disability benefits under the Social Security Act must exhaust Appointments Clause challenges before Administrative Law Judge as a prerequisite to obtaining judicial review.” The outcome is that the appeal is pending adjudication before U.S. Supreme Court.

The Decision

This case matters because a decision to allow Carr to raise an Appointments Clause in federal court that he did not mention during agency proceedings might expand the scope of judicial review. The question presented is that the U.S. Supreme Court granted petitions for writs of certiorari, and specified the following question: “Whether claimants seeking disability benefits under the Social Security Act must exhaust Appointments Clause before the Administrative Law Judge as a prerequisite to obtaining judicial review”.

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