McBride v. Commissioner of Social Security
- Edward Chen
- 3:25-cv-00666
- U.S. District Court · Northern District of California
- 3
In McBride v. Commissioner, Judge Chen dismissed the case without prejudice because McBride had not exhausted administrative remedies for interim SSI benefits.
Patricia Ann McBride’s federal-court dispute over interim conditional Supplemental Security Income benefits was dismissed without prejudice because she had not exhausted the available administrative process.
What happened
In McBride v. Commissioner of Social Security, Patricia Ann McBride sought interim Supplemental Security Income benefits while appealing decisions about her eligibility. The Social Security office had attributed excess resources to mineral-rights royalties and bingo winnings.
The government argued that McBride had an administrative process available to seek conditional benefits while her appeal was pending. The opinion states that she had not submitted the required form concerning her mineral rights and did not dispute that she had not exhausted that process.
Judge Edward Chen granted the motion to dismiss, ruling that McBride’s failure to exhaust administrative remedies deprived the court of jurisdiction over her dispute about interim conditional benefits. The court dismissed the complaint without prejudice and closed the case.
The detailed version
- McBride v. Commissioner of Social Security · No. 3:25-cv-00666
- Edward Chen
- July 15, 2025
Background
Patricia Ann McBride sought interim Supplemental Security Income (SSI) benefits while her appeal was pending. In August 2023, the Social Security field office determined that royalties connected to mineral rights placed her above the statutory resource limit for SSI eligibility. McBride agreed as part of her appeal to sell her excess resources. In July 2024, the field office also stopped her SSI benefits after determining that she had excess resources connected to $50,000 in bingo winnings. The opinion states that McBride appealed both determinations.
The defendants represented that McBride had been told she could receive conditional SSI benefits during the appeal if she either sold the resources for market value or submitted a form agreeing to sell them for market value. The field office had no evidence that she had sold the mineral rights, and the opinion states that she had not submitted the form concerning those rights. McBride challenged the cutoff of interim benefits but did not dispute that she had not exhausted the administrative process for obtaining that relief.
Motion and Analysis
The defendants moved to dismiss the complaint for failure to state a claim. The court explained that, before bringing an appeal in federal court, a claimant must exhaust the available administrative procedures under the Social Security Act. The court rejected McBride’s argument that the possibility of irreparable harm excused exhaustion. It held that she had an administrative remedy available for seeking interim conditional benefits, including submitting the necessary form to the field office.
Because McBride had not exhausted that remedy, the court held that it lacked jurisdiction over her dispute concerning interim conditional benefits. The court therefore did not reach whether she was entitled to those benefits.
Disposition
The court granted the defendants’ motion to dismiss. It dismissed McBride’s complaint without prejudice and directed the clerk to close the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.