Mazer v. Weinberger

Background

These appeals arise from cases in the Eastern District of Pennsylvania involving people who raised constitutional challenges to Title II of the Social Security Act. The opinion notes that a motion for leave to proceed without paying fees was granted in one docket. The Court vacated the lower-court judgments and sent both cases back to the district court to reexamine whether it had authority to hear the claims.

Reasoning

The central question is whether the district court may hear constitutional attacks on Title II when the administrative appeals process under 42 U.S.C. §405(g) was not completed. The Court instructed the district court to reconsider its jurisdiction in light of the Court’s decision in Weinberger v. Salfi. The ruling did not resolve the underlying constitutional claims; instead, it directed the lower court to apply the Salfi guidance when deciding if it can proceed.

Real world impact

Practically, lower courts must reassess whether they may decide similar Social Security constitutional claims or must require claimants to finish administrative steps first. The remand means these cases will return to district court for further consideration rather than ending with a final decision on the merits. The outcome may change how claimants and the agency handle exhaustion disputes.

Dissents or concurrances

Justice Brennan, joined by Justice Marshall, dissented. He explained that the records here match Salfi’s record, noted plaintiffs believed further administrative steps would be futile, and argued the court should not force exhaustion past futility and would have affirmed on the merits.