Young v. Social Security Administration, Commissioner

In 2018, plaintiff Young sought federal district court review of the Commissioner of Social Security's final decision denying disability benefits. An Administrative Law Judge (ALJ) had issued an unfavorable ruling after a hearing. On appeal, Young raised a new constitutional argument, contending that the ALJ was not properly appointed under the Appointments Clause of the U.S. Constitution, relying on the Supreme Court's recent ruling in Lucia v. SEC. The Commissioner countered that Young had forfeited this claim by failing to present it at any point during the administrative process. The court agreed, holding that timely objection is required to preserve such a structural constitutional challenge. Because Young did not raise the Appointments Clause issue before the agency, the right to judicial review of that issue was waived. Consequently, the court affirmed the Commissioner's denial of benefits.

The court ruled that Young forfeited the Appointments Clause challenge and affirmed the Commissioner's final decision denying disability benefits.

Whether a Social Security disability claimant waives the right to challenge the constitutional validity of an ALJ's appointment by failing to raise the Appointments Clause argument during the administrative hearing.

The decision reinforced the strict application of the exhaustion principle in Social Security appeals, barring belated Appointments Clause claims. It contributed to the nationwide judicial consensus prompting the Social Security Administration to formally ratify the appointments of all its ALJs in 2018, resolving widespread litigation and providing procedural finality for disability determinations.