Crawford v. Social Security Administration, Commissioner

In Crawford v. Social Security Administration, Commissioner, the plaintiff sought judicial review after an Administrative Law Judge (ALJ) denied his claim for Social Security disability benefits. Crawford argued for the first time on appeal that the ALJ was appointed in violation of the Appointments Clause of the U.S. Constitution, relying on the Supreme Court's then-recent decision in Lucia v. SEC. The United States Court of Appeals for the Eleventh Circuit issued its ruling on December 14, 2018. The court held that Crawford had failed to raise the constitutional challenge during the administrative proceedings before the agency. By not preserving the issue at the hearing level, he forfeited the right to pursue it in federal court. Consequently, the court affirmed the denial of benefits.

The court ruled that the claimant forfeited the Appointments Clause challenge by not presenting it to the agency, and the denial of disability benefits was affirmed.

Whether a Social Security disability claimant forfeits an Appointments Clause challenge to the administrative law judge's authority by failing to raise the objection during the agency's administrative proceedings.

The ruling reinforced the exhaustion requirement for constitutional claims in Social Security proceedings, limiting the scope of post-Lucia challenges. It underscored that procedural default applies to such structural objections, while the Social Security Administration had already ratified all ALJ appointments in July 2018 to resolve any constitutional defect.