Califano v. Sanders

Supreme Court of United States
430 U.S. 99 (1977)

ELI5:

Rule of Law:

The Administrative Procedure Act (APA) is not an independent grant of subject-matter jurisdiction to federal courts to review agency action. Furthermore, Section 205(g) of the Social Security Act does not authorize judicial review of the Secretary's discretionary decision not to reopen a prior final benefits determination, unless that decision is challenged on constitutional grounds.

Facts:

On January 30, 1964, respondent Sanders filed his initial claim with the Social Security Administration for disability benefits, alleging an inability to work due to epilepsy and blackout spells.
After proceeding through the administrative process, an Administrative Law Judge found Sanders ineligible for benefits.
In June 1966, the Appeals Council sustained the denial of benefits, which became the final decision of the Secretary.
Sanders did not seek judicial review of this final decision within the 60-day statutory period.
Nearly seven years later, on March 5, 1973, Sanders filed a second claim for benefits, alleging the same disabilities.
An Administrative Law Judge treated the second application as a request to reopen the prior decision and denied it, concluding the new evidence was merely repetitive and cumulative and that the claim was barred by res judicata.

Procedural Posture:

Sanders filed a civil action in the U.S. District Court for the Northern District of Indiana, challenging the Secretary's decision not to reopen his claim.
The District Court (trial court) dismissed the complaint, finding it lacked subject-matter jurisdiction.
Sanders, as appellant, appealed to the U.S. Court of Appeals for the Seventh Circuit.
The Court of Appeals (intermediate appellate court) reversed the District Court's dismissal.
The Court of Appeals held that while the Social Security Act did not grant jurisdiction, § 10 of the Administrative Procedure Act provided an independent basis for jurisdiction.
The Secretary of Health, Education, and Welfare, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does § 10 of the Administrative Procedure Act or § 205(g) of the Social Security Act grant federal district courts subject-matter jurisdiction to review a decision by the Secretary of Health, Education, and Welfare not to reopen a previously adjudicated claim for benefits?

Opinions:

Majority - Justice Brennan

No. Neither the Administrative Procedure Act (APA) nor the Social Security Act (SSA) provides a jurisdictional basis for federal courts to review the Secretary's refusal to reopen a prior benefits claim. First, the APA is not an independent grant of subject-matter jurisdiction. Congress's 1976 amendment to 28 U.S.C. § 1331, which eliminated the amount-in-controversy requirement for suits against the U.S., filled the jurisdictional gap that had led some courts to interpret the APA as a jurisdictional grant. The preservation of the SSA's preclusion statute, § 205(h), indicates Congress's intent that § 1331, not the APA, would define the contours of federal question jurisdiction over agency action. Second, § 205(g) of the SSA only permits review of a 'final decision of the Secretary made after a hearing.' A decision not to reopen a claim may be made without a hearing and is therefore not the type of 'final decision' contemplated by the statute. Allowing review of a reopening denial would frustrate Congress's clear intent to impose a 60-day statute of limitations on appeals from the original final decision. The exception for constitutional claims recognized in cases like Weinberger v. Salfi does not apply here, as Sanders raises no constitutional challenge.

Concurring - Justice Stewart

No. The court need not decide whether the APA is a general grant of jurisdiction because the Social Security Act itself resolves this case. Section 205(h) of the SSA states that no decision of the Secretary shall be reviewed 'except as herein provided.' This language unequivocally forecloses any alternative sources of jurisdiction, including the APA, for claims arising under the Social Security Act. Therefore, the only possible basis for review is § 205(g) of the Act. As the majority correctly explains, § 205(g) does not authorize review of the Secretary's refusal to reopen a prior decision. The analysis should end there.

Analysis:

This decision resolved a significant circuit split by definitively holding that the Administrative Procedure Act does not independently confer subject-matter jurisdiction upon federal courts. It firmly channeled judicial review of agency actions through specific statutory grants or general federal question jurisdiction under 28 U.S.C. § 1331. For Social Security law, the case reinforces the principle of finality in administrative decisions by closing a potential loophole; claimants cannot bypass the strict 60-day deadline for appealing an initial denial by later filing a petition to reopen and then seeking judicial review of that petition's denial. The ruling solidifies § 205(g) of the Social Security Act as the exclusive jurisdictional path for most benefit claims, with a narrow exception for constitutional challenges.

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