Eichie v. Kuakazi

Background

Peter Eichie, representing himself, sued Kilolo Kuakazi, the Acting Commissioner of Social Security, seeking a court order requiring the Social Security Administration to enforce a May 2021 decision awarding him Supplemental Security Income benefits. Eichie sought faster payment of his arrears, retroactive correction of his benefits records, review of certain medical, housing, and other expenses, and reinstatement of Terri Simmons as his representative payee.

Ruling

The Commissioner moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), which address subject-matter jurisdiction and failure to state a legally sufficient claim. The Commissioner alternatively moved for summary judgment, but the court did not decide that alternative motion.

Installment payments and the May 2021 decision

The court held that it lacked jurisdiction to review the May 2021 decision or the decision to pay the arrears in installments. The decision was fully favorable to Eichie, and the court stated that federal judicial review under the Social Security Act does not cover a decision favorable to the claimant. The court also held that the decision was not final for judicial-review purposes because Eichie did not appeal it to the Social Security Appeals Council. The court declined to waive that exhaustion requirement because Eichie’s claim directly concerned benefits, exhaustion would not be futile, and he was receiving current benefits and expected to receive the remaining arrears.

The court also rejected mandamus jurisdiction. Mandamus is an extraordinary court order requiring a federal official or agency to perform a clear, nondiscretionary duty. The court found that Eichie had not shown a clear right to a different distribution of his back payments, that any increase based on documented debts and expenses appeared discretionary, or that he lacked another adequate remedy.

Representative payee and records

The court held that the request to reinstate Simmons as representative payee was not judicially reviewable because the denial of a request to become a representative payee is excluded from administrative and judicial review. The court also held that this request was moot because Simmons had been reinstated by June 28, 2022.

The request for an award letter was moot because the Social Security Administration had sent letters describing Eichie’s reinstated benefits and payment schedule. The court further held that it lacked jurisdiction to order the agency to revise its administrative records because the content and updating of agency paperwork were non-reviewable administrative actions.

Claim for monetary relief

The court construed Eichie’s request for payment of medical, housing, and other expenses as a claim for damages beyond the past-due benefits. Applying Rule 12(b)(6), the court held that the Social Security Act does not create a private cause of action for monetary damages arising from the administrative process. The court dismissed that claim.

Disposition

The court granted the Commissioner’s motion to dismiss the complaint for lack of subject-matter jurisdiction and failure to state a claim. It did not rule on the alternative summary-judgment motion. The court dismissed the action, found that any amendment would be futile, and directed the Clerk of Court to close the case.