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Administrative Law Keyed to Aman
Smith v. Berryhill
Citation:
139 S. Ct. 1765 (2019)Facts
Ricky Lee Smith applied for disability benefits under Title XVI of the Social Security Act in 2012. His claim was denied at both the initial determination stage and upon reconsideration. Smith then requested an ALJ hearing, which was held in February 2014, after which the ALJ issued a decision denying Smith’s claim on the merits in March 2014. Smith’s attorney claimed he sent a letter requesting Appeals Council review in April 2014, well within the 60-day deadline. However, the SSA maintained it had no record of receiving this letter. In September 2014, Smith’s attorney sent a copy of the letter he had allegedly mailed earlier. The SSA treated this as the initial request, deemed it untimely, and the Appeals Council dismissed Smith’s request for review after concluding he lacked good cause for missing the deadline. This dismissal effectively ended Smith’s claim at the administrative level.
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