Jason L. Kelly v. Frank Bisignano, Commissioner of Social Security Administration
June 17, 2026·25-3214·Panel Decision·By Raj Patel
The United States Court of Appeals for the Eighth Circuit affirmed the dismissal of Jason Kelly's employment-related action against the Social Security Administration. The court held that the district court properly dismissed the case for failure to exhaust administrative remedies and failure to state a claim.
Jason Kelly filed an employment-related action against Frank Bisignano, Commissioner of the Social Security Administration, in the United States District Court for the Eastern District of Missouri. The district court dismissed the case, citing failure to timely exhaust administrative remedies and failure to state a claim.
The court’s reasoning
The Eighth Circuit concluded that the dismissal was proper for the reasons stated by the district court. The court cited precedent establishing that failure to exhaust administrative remedies is a valid ground for dismissal. Additionally, the court found that the district court did not abuse its discretion in denying Kelly’s motion for counsel, request to supplement the record, or motion under Federal Rule of Civil Procedure fifty-nine, subsection E.
What it means going forward
This decision reinforces the requirement that plaintiffs must exhaust administrative remedies before filing employment-related actions against federal agencies. It also signals that appellate courts will defer to district courts on procedural rulings regarding counsel and supplemental filings in such cases.
