Hayward v. Commissioner of Social Security

Background

John L. Hayward, proceeding without a lawyer, challenged the Commissioner of Social Security’s decision that he was not entitled to Supplemental Security Income under Title XVI of the Social Security Act. The Commissioner moved for judgment on the pleadings, asking the court to rule based on the pleadings and administrative record.

Hayward applied for benefits in July 2016, alleging disability based on human immunodeficiency virus and depression. The Social Security Administration denied the claim. Hayward requested a hearing before an Administrative Law Judge. The agency mailed him a hearing notice and later a reminder to his last known address. Both notices explained how to request a change in the hearing and warned that missing the hearing without a good reason could lead to dismissal.

Hayward did not attend the June 11, 2018 hearing. The Administrative Law Judge dismissed his hearing request after finding that he had not appeared or provided good cause, meaning a sufficient reason, for his absence. The agency had also tried to contact him by telephone and mailed the dismissal order to the same address. Hayward acknowledged receiving the dismissal and asked the Appeals Council to review it. The Appeals Council gave him 30 days to explain his absence and provide supporting documentation.

Hayward responded that he had never received notice of the hearing, but he submitted no supporting evidence. The Appeals Council found that he had not shown good cause and denied review. The Commissioner later waived the agency-exhaustion issue and moved for judgment on the pleadings based on the agency’s procedural dismissal.

Question Before the Court

The court reviewed whether the Commissioner abused his discretion by finding that Hayward had not shown good cause for missing the hearing. The court also considered Hayward’s later assertions that he had ongoing mail problems and physical and medical limitations related to a 2011 gunshot wound.

Court’s Analysis

The court found substantial evidence that the agency sent the hearing notice, reminder, and rescheduling instructions to Hayward’s last known address. The agency also attempted alternate contact and sent a detailed dismissal notice. Hayward did not dispute that he failed to provide the Administrative Law Judge with a reason for missing the hearing.

The court concluded that Hayward’s statement to the Appeals Council—that he had not received notice—was unsupported. It also declined to consider his later assertions about a damaged mailbox and his medical conditions because he had not raised those matters before the agency and had not shown good cause for presenting them for the first time in court. The court noted that his medical conditions were not new and that his later explanation differed from the explanation in his Appeals Council letter.

The court determined that the Commissioner’s factual findings were supported by substantial evidence and that the finding of no good cause was not an abuse of discretion. The court did not decide whether Hayward was disabled or entitled to Supplemental Security Income.

Disposition

The court GRANTED the Commissioner’s motion for judgment on the pleadings and DISMISSED the case.