Williams v. Commissioner of Social Security

Background

Janice Williams, appearing without a lawyer, brought an action under 42 U.S.C. § 405(g), which allows federal-court review of a final decision by the Commissioner of Social Security made after a hearing. The opinion does not identify the benefits at issue or describe the underlying administrative decision.

Jurisdiction and exhaustion

The court explained that a claimant generally must complete the Social Security Administration’s administrative review process before seeking review in federal court. The process includes receiving an initial determination, seeking reconsideration, requesting a hearing before an administrative law judge, and asking the Appeals Council to review the administrative law judge’s decision. A final decision generally exists after the Appeals Council issues its decision, or when the Appeals Council denies review and the administrative law judge’s decision becomes final.

The court found that Williams’s complaint did not clearly allege that she had exhausted these steps or received a final decision from the Commissioner. It also did not include facts showing that any failure to exhaust should be excused. Because the complaint did not allege facts establishing the court’s jurisdiction under § 405(g), the case could not proceed at that time.

Order

The court granted Williams leave to amend her complaint. It ordered her to use the court’s Social Security complaint form and provide the date of the administrative law judge’s decision, the date of the Appeals Council letter, and the date she received that letter. She also had to attach a copy of the Appeals Council letter. If she had not exhausted the administrative process, she had to provide facts supporting an excuse from that requirement.

The amended complaint was required to completely replace, rather than supplement, the original complaint. Williams had 60 days from the date of the order to submit it to the court’s Pro Se Intake Unit, label it “Amended Complaint,” and include docket number 20 Civ. 5991. The court stated that if she failed to comply and could not show good cause for the failure, the complaint would be dismissed for failure to state a claim. No summons would issue at that time.

Judge Lorna G. Schofield also certified that any appeal from the order would not be taken in good faith and denied Williams fee-free appeal status. The order directed the Clerk of Court to mail Williams a copy and record service on the docket. The court did not decide whether Williams was entitled to benefits or whether the Commissioner’s decision was legally or factually correct.