Justina S. v. Kijakazi

Background

Justina S. applied for disability benefits and supplemental security income from the Social Security Administration. After a hearing, an Administrative Law Judge denied her claim. That decision became the final decision of the Commissioner of Social Security, and Justina S. sought judicial review under 42 U.S.C. § 405(g). The parties filed cross-motions for summary judgment, meaning each asked the court to rule in its favor without a trial.

Arguments

Justina S. argued that the Administrative Law Judge was an “inferior officer” whose appointment violated the Constitution’s Appointments Clause. She also argued that, even if the appointment was valid, the denial of benefits was not supported by substantial evidence, meaning sufficient relevant evidence in the record.

The Commissioner argued that Justina S. had forfeited or waived the Appointments Clause challenge by not raising it during the administrative proceedings. The Commissioner also argued that the Administrative Law Judge’s decision was properly decided.

Court’s action

The Eighth Circuit had consolidated appeals involving the waiver issue. The court concluded that waiting for those appeals would simplify the case, conserve judicial resources, and not severely prejudice Justina S. It therefore stayed the matter pending the outcome of the consolidated appeals.

The court did not decide the parties’ competing summary-judgment motions or the merits of Justina S.’s disability claim. It also declined to rule at that time on her request for limited supplemental briefing, while allowing her to renew that request when the parties sought to lift the stay. The parties were ordered to contact the court within 14 days after the Eighth Circuit decided the related appeals to request that the stay be lifted or seek other appropriate relief.