Williams v. Commissioner of Social Security
- Susan Van Keulen
- 5:21-cv-07822
- U.S. District Court · Northern District of California
- 3
In Williams v. Commissioner of Social Security, Judge Van Keulen ordered briefing on possible jurisdiction because Williams waived his disability-benefits hearing.
Timothy Williams and the Commissioner of Social Security; the order required briefing on whether the federal court has jurisdiction and postponed consideration of Williams’s motion to supplement the administrative record.
What happened
Williams v. Commissioner of Social Security concerns Timothy Williams’s request for court review of a Social Security disability-benefits decision. Williams filed the case without a lawyer and relied on a law that allows review of a final agency decision made after a hearing.
The record showed that Williams requested an Administrative Law Judge hearing, but at the hearing he asked, through his representative, to withdraw that request. The Administrative Law Judge dismissed the hearing request, and the Appeals Council denied review. The court therefore questioned whether Williams received the type of hearing required for federal court jurisdiction.
The court did not decide whether it has jurisdiction. Judge Susan Van Keulen ordered the Commissioner to file a brief, Williams to respond, and deferred ruling on Williams’s motion to supplement the administrative record until the jurisdiction issue is resolved.
The detailed version
- Williams v. Commissioner of Social Security · No. 5:21-cv-07822
- Susan Van Keulen
- Nov. 7, 2022
Background
Timothy Williams sued the Commissioner of Social Security seeking review of what he described as a final decision concerning his disability benefits. Williams acted without a lawyer. His complaint invoked 42 U.S.C. § 405(g), which permits a person to seek federal-court review of a final Commissioner decision made after a hearing.
The Commissioner’s answer admitted, among other things stated in the opinion, that Williams had exhausted the required administrative remedies and filed the action timely.
Record concerning the hearing
Williams requested a hearing before an Administrative Law Judge on March 17, 2017. At a February 7, 2018 hearing, Williams, through his representative, asked to withdraw his hearing request. The Administrative Law Judge then dismissed the hearing request in an order dated February 14, 2018. The Appeals Council denied Williams’s request for review.
The court stated that the record therefore appeared to show that Williams did not receive an Administrative Law Judge hearing on the merits of his disability-benefits claim because he waived it.
Court’s action
While reviewing Williams’s motion to supplement the administrative record, the court raised a concern about subject-matter jurisdiction. Subject-matter jurisdiction is the court’s legal authority to decide a case. The court explained that it has an independent duty to ensure that this authority exists, even though neither party had raised the issue.
The court ordered the parties to brief whether § 405(g) gives the court jurisdiction in light of Williams’s waiver of an Administrative Law Judge hearing. Although the party invoking federal jurisdiction ordinarily bears responsibility for addressing it, the court required the Commissioner to file the opening brief because Williams was representing himself. The Commissioner’s brief was due December 7, 2022, and Williams’s response was due January 23, 2023; the court stated that it would set a hearing if necessary.
Judge Susan Van Keulen deferred ruling on Williams’s pending motion to supplement the administrative record until the court determines whether subject-matter jurisdiction exists. The order did not decide whether jurisdiction exists and did not decide the merits of Williams’s disability-benefits claim.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.