Califano v. Sanders

Background

A man who had applied for Social Security disability benefits first filed in 1964 and was denied after agency hearings and appeals. He did not sue then. In 1973 he filed the same claim; the agency treated it as either barred or as asking to reopen the earlier denial, and it denied reopening because the evidence was repetitive. He sued in federal district court claiming jurisdiction under the Social Security Act’s review provision, §205(g). The District Court dismissed for lack of jurisdiction, the Court of Appeals reversed relying on the Administrative Procedure Act’s §10 as an independent source of jurisdiction, and the Supreme Court agreed to decide the legal question.

Reasoning

The Court addressed two questions: whether §10 of the Administrative Procedure Act is an independent grant of subject‑matter jurisdiction, and whether §205(g) of the Social Security Act allows courts to review a refusal to reopen a benefits decision. The Court held that §10 is not an implied jurisdictional grant, especially after Congress revised federal‑question jurisdiction in 1976, and that §205(g) limits judicial review to final agency decisions made after a hearing. Because a refusal to reopen may be denied without a hearing and the statute’s §205(h) preserves limitations, the Court ruled that federal courts lack jurisdiction to review the agency’s decision not to reopen this claimant’s prior denial.

Real world impact

This means people whose earlier Social Security denials are later refused reopening generally cannot get a new federal-court review just by filing a reopening request. Judicial review remains available for final decisions after hearings and for constitutional claims, but routine reopening denials are not a route into federal court.

Dissents or concurrances

Justice Stewart, joined by the Chief Justice, agreed with the outcome but wrote separately. He emphasized that §205(h) of the Social Security Act plainly bars review of Secretary decisions except as §205(g) allows, so reopening denials fall outside judicial review.