Carr v. Saul

Carr v. Saul,, 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.

Background

Six petitioners who applied for disability benefits were denied by the Social Security Administration. They each unsuccessfully challenged their respective adverse benefit determination in a hearing before an SSA administrative law judge. 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.