VanRyn Rodriguez v. Commissioner of Social Security
- Andrew Krause
- 7:17-cv-04038
- U.S. District Court · Southern District of New York
- 2
Mayte VanRynRodriguez v. Saul: Judge Krause ordered a Social Security remand for a new hearing before a different judge after an Appointments Clause challenge.
Mayte VanRynRodriguez and the Social Security Administration. The agency must reconsider the case before a different administrative law judge, provide a new hearing, and issue a new decision.
What happened
In Mayte VanRynRodriguez v. Andrew Saul, the plaintiff challenged the handling of her Social Security case and raised a claim under the Constitution’s Appointments Clause. The judgment states that the parties’ May 27, 2021 stipulation and order supported sending the case back to the Social Security Administration.
The court reversed the agency’s decision and remanded the case for further administrative proceedings under a provision of the Social Security law. The remand followed the Supreme Court’s decision in Carr v. Saul, which held that a claimant may raise an Appointments Clause claim for the first time in federal court.
The Social Security Administration’s Appeals Council must assign the case to a different administrative law judge, provide a new hearing, and issue a new decision. Judge Andrew Krause is identified in the supplied case information.
The detailed version
- VanRyn Rodriguez v. Commissioner of Social Security · No. 7:17-cv-04038
- Andrew Krause
- May 27, 2021
Background
Mayte VanRynRodriguez brought this action against Andrew Saul, the Commissioner of Social Security. The judgment states that the parties’ stipulation and order dated May 27, 2021, provided the reasons for the court’s action. The plaintiff raised a claim under the Appointments Clause, a constitutional provision concerning the appointment of certain federal officers.
Ruling
The court reversed the agency’s decision and remanded the action to the Commissioner of Social Security for further administrative proceedings under sentence four of 42 U.S.C. § 405(g). A sentence-four remand sends the case back to the agency based on the court’s ruling.
The judgment relied on Carr v. Saul, 141 S. Ct. 1352 (2021), in which the Supreme Court held that a Social Security claimant does not have to raise an Appointments Clause claim before the agency and may raise it for the first time in federal court. The judgment states that Mayte VanRynRodriguez raised that claim in federal court.
Required proceedings on remand
The Appeals Council must assign Mayte VanRynRodriguez’s case to a different administrative law judge, offer a new hearing, and issue a new decision.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.