Carr v. Saul

Summary

The Court held that Social Security disability claimants did not forfeit their Appointments Clause challenges by failing to raise them before agency administrative law judges. The inquisitorial character of the proceedings, the constitutional nature of the challenges, and the adjudicators’ inability to provide relief counseled against judicially imposing issue exhaustion. The Court also rejected the argument that the challenges were untimely merely because they were first raised in federal court, and reversed and remanded the Eighth and Tenth Circuit judgments. Justice Sotomayor’s opinion had five votes throughout, with additional Justices joining specified portions. Justice Thomas, joined by Justices Gorsuch and Barrett, concurred in part and in the judgment, concluding that the nonadversarial character of SSA proceedings alone resolved the exhaustion question. Justice Breyer concurred in part and in the judgment, relying on exceptions for constitutional and futile claims while maintaining that issue exhaustion ordinarily applies despite the proceedings’ nonadversarial nature.