Sims v. Apfel

No. 98-60126 (5th Cir. Aug. 15, 2000); 120 S.Ct. 2080 (U.S. June 5, 2000) ; Clearinghouse Number: 53049

Description

Supreme Court Holds That Social Security Claimants Need Not Exhaust Issues to Preserve Them for Judicial Review

Abstract

The U.S. Supreme Court held that social security claimants who exhausted administrative remedies need not present issues in a request for Appeals Council review in order to preserve judicial review of those issues. Petitioner, alleging a variety of ailments, applied for disability and Supplemental Security Income benefits under the Social Security Act. The state agency and an administrative law judge denied her claims. The Appeals Council denied her request for review, and the district court affirmed denial of benefits. In an unpublished opinion, the Fifth Circuit affirmed, concluding that it lacked jurisdiction over two of petitioner’s three contentions on the administrative law judge’s errors because petitioner had not raised them in her request for review by the Appeals Council. Reversing and remanding the Fifth Circuit opinion, the Supreme Court noted that neither statute nor regulations required issue exhaustion. It found that, in the absence of a statute or regulation, an issue-exhaustion requirement might be judicially imposed as an analogy to the rule that appellate courts would not consider arguments not raised before trial courts. Where the parties were expected to develop the issues in an adversarial administrative proceeding, the rationale for requiring issue exhaustion was at its greatest; where an administrative proceeding was not adversarial, the reasons for a court to require issue exhaustion were much weaker. In this case, because Social Security Administration review proceedings were informal, nonadversarial, investigative proceedings in which the Appeals Council, not claimant, had primary responsibility for identifying and developing the issues, the Supreme Court held that a judicially created issue-exhaustion requirement was inappropriate.

Additional Information

Attorney Information
Plaintiff represented by Sarah H. Bohr, 2337 Seminole Rd., Atlantic Beach, FL 32233 (904.246.7603); Chantal J. Harrington, 4859 Mariner Point Dr., Jacksonville, FL 32225 (904.997.9272); Gary R. Parvin, Route 2, Box 149C, Coffeeville, MS 38922 (601.626.6648)
Docket Date
2000-08-15 00:00:00+00:00