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Amicus Briefs

Carr v. Saul; Davis v. Saul

The case concerned whether claimants seeking disability benefits under the Social Security Act had to “exhaust” constitutional challenges to their benefits determinations before an Administrative Law Judge (ALJ) at the Social Security Administration in order to obtain judicial review on that issue on later appeal in federal court.

Specifically, the Petitioners did not challenge the constitutionality of their ALJs’ appointments during their respective ALJ hearings, but they each raised a constitutional challenge on appeal in district court. The Eighth and Tenth U.S. Circuit Courts of Appeals closed the courthouse doors on the Petitioners’ Appointments Clause challenges, ruling that “issue exhaustion” precluded a challenge that was not first raised before the ALJ.

In January 2021, NCLA and the Cato Institute filed a joint amicus brief arguing that imposing issue exhaustion requirements is inappropriate when the issue does not depend on an agency’s discretion, expertise, or fact-finding.

In a win for NCLA, on April 22, 2021, the U.S. Supreme Court unanimously held that the lower courts erred in imposing an issue-exhaustion requirement on Social Security disability claimants. In Carr v. Saul, claimants challenged a judge-made version of the administrative exhaustion rule requiring that litigants at an administrative hearing raise any legal arguments in support of their claim at each step of the administrative process or forfeit those arguments on appeal.

Mark Chenoweth
President and Chief Legal Officer
NCLA FILINGS

Opinion of the U.S. Supreme Court

April 22, 2021 | Read More

Supreme Court Oral Argument in Carr v. Saul

March 3, 2021 | Read More

Amici Curiae Brief of the New Civil Liberties Alliance & Cato Institute in Support of Petitioners

January 4, 2021 | Read More

PRESS RELEASES

In Victory for NCLA, Supreme Court Unanimously Rejects “Issue Exhaustion” Requirement before ALJ

April 22, 2021 | Read More

NCLA Discourages Supreme Court from Upholding “Issue Exhaustion” in Social Security Benefits Cases

January 4, 2021 | Read More

IN THE MEDIA

The Hamburger Court

The New York Sun

February 8, 2023

Justices Resolve Circuit Split on Challenges to Judge Appointments

Courthouse News Service

February 8, 2023

Stop Protecting Unconstitutional Judges

Washington Examiner

February 8, 2023

It’s Time to Stop Protecting Unconstitutional Judges

Cato Institute

February 8, 2023

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