Smith v. Berryhill
In brief
Smith won the access-to-court question: a late-appeal dismissal after an ALJ hearing can be reviewed by a federal court.
- Where it stands
- Decided
Decided 9-0 · May 28, 2019 · Opinion by Justice Sotomayor
- What it’s about
- The Supreme Court ruled that the Social Security Administration’s Appeals Council made a decision federal courts could review when it rejected Ricky Lee Smith’s disability-benefit appeal as late after a hearing before an administrative law judge.
- Who it affects
- The ruling lets claimants seek federal-court review of this type of Appeals Council timing decision. It does not decide whether Ricky Lee Smith qualifies for disability benefits.
Summary: written with AI from the case record.
What it's about
The Court overturned the Sixth Circuit’s ruling and sent the case back to the lower court (remanded), without deciding whether Smith should receive benefits.
The case concerns when a Social Security agency action is final enough for a federal court to review it under Section 405(g).
Question presented
Whether the Appeals Council's decision to reject a disability claim on the ground that the claimant's appeal was untimely is a "final decision" subject to judicial review under Section 405(g).
What the Court decided
Holding
An Appeals Council dismissal on timeliness grounds after a claimant has had an ALJ hearing on the merits qualifies as a “final decision . . . made after a hearing” for purposes of allowing judicial review under §405(g). 880 F. 3d 813, reversed and remanded.
- Result
- Reversed
The vote
What's next
The case returns to the lower court for proceedings consistent with the Supreme Court's ruling. Smith's underlying request for disability benefits was not resolved by this decision.
Documents
Docket activity
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More questions
- What did the Supreme Court decide in Smith v. Berryhill?
- The Court decided that an Appeals Council dismissal for late filing can be reviewed in federal court after an ALJ hearing.
- Who won Smith v. Berryhill?
- Ricky Lee Smith won the legal question about access to federal court. The Court overturned the Sixth Circuit's ruling.
- Did the Court decide whether Smith gets disability benefits?
- No. The decision addressed whether a federal court may review the Appeals Council's late-filing dismissal, not Smith's benefit eligibility.
- What happens next in Smith v. Berryhill?
- The Court sent the case back to the lower court (remanded). That court must proceed under the Supreme Court's rule.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.