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Smith v. Berryhill

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Supreme Court of the United States
Smith v. Berryhill
Term: 2018
Important Dates
Argument: March 18, 2019
Decided: May 28, 2019
Outcome
Reversed and remanded
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh

Smith v. Berryhill is a case argued before the Supreme Court of the United States on March 18, 2019, during the court's 2018-2019 term. The case concerned the Social Security Administration’s Appeals Council. On May 28, 2019, the court reversed and remanded the ruling of the United States Court of Appeals for the 6th Circuit, holding that the Social Security Administration Appeals Council's dismissal of a claim for untimeliness permits judicial review in a U.S. federal court under 42 United States Code §405(g).[1] Click here for more information. The case came on a writ of certiorari to the 6th Circuit.[2]

HIGHLIGHTS
  • The case: The Social Security Administration’s Appeals Council denied a renewal of Ricky Lee Smith's application for supplemental security income (SSI) resulting from disability. The council said Smith did not file his claim on time. Smith alleged that he suffered due process violations, but the district court and the Sixth Circuit Court disagreed.
  • The issues: Whether the Appeals Council's decision to reject a disability claim on the ground that the claimant's appeal was untimely is a "final decision" subject to judicial review under Section 405(g).[3]
  • The outcome: The court reversed and remanded the ruling of the United States Court of Appeals for the 6th Circuit, holding that the Social Security Administration Appeals Council's dismissal of a claim for untimeliness permits judicial review in a U.S. federal court under 42 United States Code §405(g).[1]


    • You can review the lower court's opinion here.[4]

    Why it matters: Smith v. Berryhill is an example of the U.S. Supreme Court declining to apply Chevron deference.[1][5] Chevron deference comes from a 1984 decision that said courts should uphold reasonable agency interpretations of ambiguous laws. In this case, the court held that the scope of judicial review available to someone facing an administrative agency is not the kind of question Congress would leave for an agency to decide without expressly saying so.[1][5] The ruling also clarified when people may challenge decisions made by Social Security Administration officials in court.[5]

    Timeline

    The following timeline details key events in this case:

    • May 28, 2019: U.S. Supreme Court reversed and remanded the 6th Circuit Court's ruling.
    • March 18, 2019: Oral argument
    • November 2, 2018: U.S. Supreme Court agreed to hear case
    • May 25, 2018: Petition filed with U.S. Supreme Court
    • January 26, 2018: Sixth Circuit Court affirmed the order of the district court

    Background

    In 1988, Ricky Lee Smith's application for supplemental security income (SSI) resulting from disability was approved by a judge, and he received benefits until 2004. His benefits expired because he was over the resource limit. Smith then filed a second application in August 2012, but the claim was denied. Smith then claimed "to have mailed a written request for review before the Appeals Council on April 24, 2014, and followed up by fax on September 21, 2014. A claims representative spoke with Smith on October 1, 2014, to inform him that his request may not have been received and that his request was filed as of that day, October 1, 2014," according to Oyez.[6]

    The Social Security Appeals Council dismissed his request for review because the agency said that Smith did not file his claim on time. Smith then filed a civil action to review the dismissal of his claim. The district court dismissed Smith's complaint, citing lack of jurisdiction.[6]

    Smith alleged "that he suffered due process violations because: (1) his request for Appeals Council review was timely submitted but dismissed as untimely, (2) a different ALJ signed his hearing decision than the one that presided over his hearing, and (3) the ALJ referenced Smith's 1988 favorable supplemental security income decision in his unfavorable decision denying income for new medical conditions, but failed to attach a copy of it as an exhibit." The Sixth Circuit Court affirmed the order of the district court and found that Smith's right to due process was not violated.[4]

    Smith appealed to the Supreme Court, and the court agreed to hear the case on November 2, 2018.

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions presented:
    • Whether the Appeals Council's decision to reject a disability claim on the ground that the claimant's appeal was untimely is a "final decision" subject to judicial review under Section 405(g).

    Outcome

    In a 9-0 opinion, the court reversed and remanded the ruling of the United States Court of Appeals for the 6th Circuit, holding that the SSA Appeals Council's dismissal of a claim for untimeliness permits judicial review in a U.S. federal court under 42 United States Code §405(g).[1]

    Justice Sonia Sotomayor delivered the opinion of the court.[1]

    Opinion

    In her opinion, Justice Sotomayor wrote:[1]

    “ We hold that where the SSA's Appeals Council has dismissed a request for review as untimely after a claimant has obtained a hearing from an ALJ on the merits, that dismissal qualifies as a "final decision . . . made after a hearing" within the meaning of §405(g). The judgment of the United States Court of Appeals for the Sixth Circuit is therefore reversed, and the case is remanded for further proceedings consistent with this opinion. [7] ”

    Text of the opinion

    Read the full opinion here.

    Audio

    Audio of oral argument:[8]


    Transcript

    Transcript of oral argument:[9]

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, Smith v. Berryhill, May 28, 2019
    2. ↑ Supreme Court of the United States, "17-1606 Smith v. Berryhill," accessed February 13, 2019
    3. ↑ 3.0 3.1 Supreme Court of the United States, "17-1606 Smith v. Berryhill," accessed February 13, 2019
    4. ↑ 4.0 4.1 SCOTUSblog, "Smith v. Berryhill," accessed February 13, 2019
    5. ↑ 5.0 5.1 5.2 SCOTUSblog, "Opinion analysis: Dismissal as untimely of Supplemental Security Income claimant’s request for review is final decision subject to judicial review," May 29, 2019
    6. ↑ 6.0 6.1 Oyez, "Smith v. Berryhill," accessed February 14, 2019
    7. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, Smith v. Berryhill, argued March 18, 2019
    9. ↑ Supreme Court of the United States, Smith v. Berryhill, argued March 18, 2019
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