Carr v. Saul

Carr v. Saul
Argued March 3, 2021
Decided April 22, 2021
Full case nameWillie Earl Carr, et al. v. Andrew M. Saul, Commissioner of Social Security
John J. Davis, et al. v. Andrew M. Saul, Commissioner of Social Security
Docket nos.19-1442
20-105
Citations593 U.S. ___ (more)
ArgumentOral argument
Holding
A petitioner need not challenge the constitutionality of an agency's structure under the Appointments Clause in an internal agency administrative proceeding in order to present that challenge in court on appeal.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan · Neil Gorsuch
Brett Kavanaugh · Amy Coney Barrett
Case opinions
MajoritySotomayor, joined by Roberts, Alito, Kagan, Kavanaugh; Thomas, Gorsuch, Barrett (Parts I, II–A, and II–B–2); Breyer (Parts I, II–B–1, and II–B–2)
ConcurrenceThomas (in part and in the judgment), joined by Gorsuch, Barrett
ConcurrenceBreyer (in part and in the judgment)
Laws applied
U.S. Const. art. II, § 2, cl. 2

Carr v. Saul, 593 U.S. ___ (2021), was a United States Supreme Court case in which the court held that a petitioner need not challenge the constitutionality of an agency's structure under the Appointments Clause in an internal agency administrative proceeding in order to present that challenge in court on appeal.[1][2]

Background

Six petitioners (including Carr) who applied for disability benefits were denied by the Social Security Administration (SSA). They each unsuccessfully challenged their respective adverse benefit determination in a hearing before an SSA administrative law judge (ALJ). The SSA Appeals Council denied discretionary review in each case. Thereafter, the Supreme Court decided Lucia v. SEC, which held that the appointment of Securities and Exchange Commission ALJs by lower level staff violated the Constitution's Appointments Clause. Because the SSA ALJs who denied these claims were also appointed by lower level staff, petitioners argued in federal court that they were entitled to a fresh administrative review by constitutionally appointed ALJs. In each case, the Court of Appeals held that petitioners could not obtain judicial review of their Appointments Clause claims because they failed to raise those challenges in their administrative proceedings.

Opinion of the court

The Supreme Court issued an opinion on April 22, 2021.[1]

Later developments

References

  1. ^ a b Carr v. Saul, 593 U.S. ___ (2021).
  2. ^ Mann, Ronald (April 23, 2021). "Justices decisively reject imposing issue exhaustion on Social Security claimants". SCOTUSblog. Retrieved December 28, 2025.

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain.