Califano v. Sanders

Supreme Court of the United States · 1977 · Administrative Law

Administrative LawJudicial ReviewSocial SecurityAPAsubject-matter jurisdictionjudicial reviewSocial Security ActSection 205(g)

Facts

Respondent filed an initial claim for disability benefits in 1964, alleging epilepsy and blackout spells. An Administrative Law Judge found him ineligible, the Appeals Council affirmed in 1966, and respondent did not seek judicial review under § 205(g). Nearly seven years later, he filed a second claim on the same basis; the Administrative Law Judge treated it as barred by res judicata, considered whether to reopen the prior claim, found the new evidence merely repetitive and cumulative with no errors on the face of the evidence, and denied reopening. Respondent then filed suit in federal court challenging the refusal to reopen.

Issue

Does § 10 of the Administrative Procedure Act independently grant federal district courts subject-matter jurisdiction to review the Secretary's refusal to reopen a previously adjudicated Social Security benefits claim? If not, does § 205(g) of the Social Security Act authorize judicial review of that refusal to reopen?

Rule

APA § 10 is not an implied grant of subject-matter jurisdiction for federal judicial review of agency action. Under the Social Security Act, § 205(g) authorizes review only of a 'final decision of the Secretary made after a hearing,' and it does not permit judicial review of the Secretary's discretionary refusal to reopen a prior benefits determination; an exception exists for colorable constitutional claims, for which judicial review is presumed absent clear and convincing evidence of congressional preclusion.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, Lena Ortiz asked the Federal Housing Records Board to reverse a six-year-old benefits determination. The Board declined, and Lena filed suit in federal district court alleging that APA §§ 702-704 entitled her to judicial review, but she identified no other jurisdictional statute.

Should the district court treat the APA alone as an independent grant of subject-matter jurisdiction?

Explanation. The majority held that APA § 10 is not an implied grant of subject-matter jurisdiction. Its text provides for judicial review in a court otherwise made competent to hear the case, but it does not itself open the federal courthouse doors. So a plaintiff invoking only the APA has not established jurisdiction.