Bowen v. City of New York

Background

The City of New York, its public hospitals, two state officials, and several disabled individuals sued the federal Social Security agency and its Secretary. They alleged that an internal, unpublished SSA policy led state reviewers and administrative judges to presume that mentally impaired applicants who did not meet the agency’s medical listings could nevertheless do unskilled work. The suit challenged denials and terminations of SSD and SSI benefits between April 1, 1980 and May 15, 1983, affecting tens of thousands of New Yorkers. The District Court found that SSA followed the covert policy and that it had been applied widely, denying individualized work-capacity assessments.

Reasoning

The Supreme Court addressed whether the district court could include in the class people who had not exhausted administrative appeals or who missed the 60-day filing window for court review. The Court held the 60-day rule is a statute of limitations, not a strict jurisdictional bar, and that equitable tolling applies when the Government’s secret conduct prevents claimants from knowing of a legal wrong. The Court also held that exhaustion of administrative remedies could be excused where a widespread undisclosed policy made exhaustion futile and would cause irreparable harm. The Court affirmed the lower courts’ rulings.

Real world impact

Because the Court allowed tolling and excused exhaustion here, the Secretary was ordered to reopen affected claims, and the district court had required interim reinstatement of benefits for some terminated class members until proper review. The ruling clears the way for thousands of disabled New Yorkers to seek administrative reconsideration under correct procedures. The decision also signals that undisclosed, systemic agency practices that prevent claimants from learning of violations may justify equitable relief and procedural exceptions in future cases.