Background
Kelvin Wells applied for disability insurance benefits under Title Two of the Social Security Act. The Social Security Administration denied his application. After an administrative law judge hearing and an Appeals Council remand for additional factfinding, the claim remained pending at the field office. Wells sought judicial review in federal district court, which dismissed the case for failure to exhaust administrative remedies.
The court’s reasoning
The court held that the Social Security Act requires claimants to exhaust four steps of administrative review before seeking federal court review. Because the Appeals Council remanded the claim for further evidentiary development, there was no final decision available for judicial review. The court noted that while exhaustion is nonjurisdictional, the district court properly dismissed the claim because the administrative process was not complete.
What it means going forward
Claimants must complete all administrative steps including Appeals Council review before filing in federal court, even if the agency remands the case for further development.