For many Social Security disability benefits claimants, the claim process is a long and complicated affair. In Aruanno v. Commissioner of Social Security, however, the Third Circuit Court of Appeal explains that a claimant must follow through with this process before seeking relief in federal court.
The Social Security Administration (SSA) awarded Plaintiff Joseph Aruanno Social Security Disability Insurance (SSDI) benefits in July 1995. Almost a year and a half later, Plaintiff was convicted in a New Jersey state court of second-degree sexual assault and incarcerated. Because of his incarceration, SSA suspended Plaintiff's disability benefits. In 2004, Plaintiff was transferred from prison to civil detention unit where he still resided at the time of the court's opinion.
After the transfer, Plaintiff requested by letter to SSA that his SSDI benefits be restored. The SSA rejected this request and did not respond to a subsequent 2007 letter in which Plaintiff again requested that his benefits be restored. Plaintiff then filed the instant action in U.S. District Court for the District of New Jersey, asking the court to compel the SSA to restore his benefits. The court dismissed the action for lack of subject matter jurisdiction.
On appeal, the Third Circuit upheld the District Court's ruling, agreeing that it lacked subject matter jurisdiction over the matter because the SSA had not reached a 'final decision' on Plaintiff's request that his benefits be restored.
42 U.S.C. § 405(g) sets a federal district court's jurisdiction over Social Security disability appeals as follows
Any individual, after any final decision of the Commissioner of Social Security made after a hearing to which he was a party...may obtain a review of such decision by a civil action commenced within sixty days after the mailing to him of notice of such decision or within such further time as the Commissioner of Social Security may allow. Such action shall be brought in the district court of the United States for the judicial district in which the plaintiff resides.
Thus, a district court's jurisdiction is limited to actions for which the Commissioner has reached a "final decision."
The court explained that "an individual claiming entitlement to benefits first receives an initial determination." The claimant can then seek reconsideration of this determination if he or she is not satisfied. Following reconsideration, the claimant can request an administrative hearing before an SSA Administrative Law Judge (ALJ). If dissatisfied with the ALJ's decision, the claimant can ask the SSA's Appeals Council to review the decision. The Appeals Council may decline the request or review the ALJ's decision and then issue a decision of its own. The Appeal's Council's action according to the court, constitutes the Commissioner's final decision, which the claimant can then appeal in federal court.
In this case, the Court found that the SSA did not reach a final decision on Plaintiff's request to restore his benefits before filing the action in federal court. "[N]onpayment of benefits due to incarceration is considered an initial determination," the Court ruled. Plaintiff's letters, furthermore, did not constitute a formal request for reconsideration of this decision. As a result, the district court properly ruled that it lacked jurisdiction over the matter.
A person whose disability benefits claim is initially denied (or whose benefits are suspended) may still be able to obtain benefits by allowing the claim and appeal process to play out. An experienced Social Security disability lawyer is aware of the procedures required to achieve a 'final decision' by the Commissioner and, absent some rare exceptions, would not bring suit in Federal Court until the case is 'ripe' for Federal Court action. Until that point, an experienced Social Security lawyer will provide vital assistance to a claimant by filing the claim on a client's behalf and representing the client throughout the entire appeals process: