Langley v. Social Security Administration, Commissioner

Plaintiff Tammie M. Langley applied for disability insurance benefits and supplemental security income, which were denied by an Administrative Law Judge (ALJ) after a hearing. Langley appealed to the United States District Court for the Northern District of Alabama, arguing the ALJ's appointment violated the Appointments Clause of the U.S. Constitution, relying on Lucia v. SEC. The Commissioner conceded that Social Security ALJs had been unconstitutionally appointed but argued Langley forfeited this claim by not raising it during the administrative proceedings. The court agreed, finding that Langley failed to timely challenge the ALJ's appointment before the agency, thus waiving the issue. The court further determined the ALJ's decision was supported by substantial evidence and affirmed the denial of benefits.

The district court held that the plaintiff forfeited her constitutional claim by not raising it during the agency proceedings and affirmed the Commissioner's final decision denying disability benefits.

Whether the plaintiff forfeited her Appointments Clause challenge to the Social Security ALJ's authority by failing to exhaust the issue at the administrative level before seeking judicial review.

The decision reinforced the issue exhaustion requirement in Social Security appeals, joining a growing body of precedent mandating that disability claimants timely raise Appointments Clause challenges during the administrative hearing to preserve the argument for federal court review, thereby limiting post-Lucia remands and emphasizing procedural rigor in benefit determinations.