OCTOBER TERM, 1999
Syllabus
certiorari to the united states court of appeals for the fifth circuit
No. 98-9537. Argued March 28, 2000—Decided June 5, 2000
Petitioner applied for Social Security disability and Supplemental Security
Income benefits. After a state agency denied her claims, she obtained a hearing before a Social Security Administrative Law Judge (ALJ), who also denied her claims. Petitioner then requested review by the Social Security Appeals Council, which denied review. She next filed suit in the Federal District Court, contending that the ALJ erred in three ways. The District Court rejected her contentions, and the Fifth Circuit affirmed, concluding that it lacked jurisdiction over two of the contentions because they were not included in petitioner's request for review by the Appeals Council.
Held: The judgment is reversed, and the case is remanded.
200 F. 3d 229, reversed and remanded.
Justice Thomas delivered the opinion of the Court with respect to Parts I and II-A, concluding that Social Security claimants who exhaust administrative remedies need not also exhaust issues in a request for review by the Appeals Council in order to preserve judicial review of those issues. Although administrative issue-exhaustion requirements are largely creatures of statute, there is no contention that any statute requires such exhaustion here. It is also common for an agency's regulations to require issue exhaustion in administrative appeals, but Social Security Administration (SSA) regulations do not. This Court has required issue exhaustion even in the absence of a statute or regulation, but the reason for doing so does not apply here. The desirability of a judicially imposed issue-exhaustion requirement depends on the degree to which the analogy to normal adversarial litigation applies in a particular administrative proceeding. See Hormel v. Helvering, 312 U. S. 552, 556. Where that proceeding is not adversarial, the reasons for a court to require issue exhaustion are much weaker than where the parties are expected to develop the issues themselves. Pp. 106-110.
Justice Thomas, joined by Justice Stevens, Justice Souter, and Justice Ginsburg, concluded in Part II-B that the differences between courts and agencies are nowhere more pronounced than in Social Security proceedings, which are inquisitorial rather than adversarial. The ALJ's duty is to investigate the facts and develop the arguments
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