Henley v. Social Security Administration c/o Nancy A. Berryhill

In Henley v. Social Security Administration c/o Nancy A. Berryhill, the plaintiff, identified as Henley, challenged the denial of Social Security disability benefits in the U.S. District Court for the Eastern District of Tennessee. The case stemmed from an unfavorable decision by an administrative law judge. Relying on the Supreme Court's ruling in Lucia v. SEC (2018), Henley argued that the ALJ who heard his case had been improperly appointed under the Appointments Clause of the U.S. Constitution. Because the SSA's ALJs had not been appointed by the agency head at the time, Henley contended the hearing was void and sought a new hearing before a constitutionally appointed ALJ. On October 3, 2018, the magistrate judge issued a report and recommendation addressing the constitutional challenge and the merits of the disability claim.

The magistrate judge recommended that the plaintiff's case be remanded to the Social Security Administration for a new hearing before a different, constitutionally appointed administrative law judge.

Whether the Social Security Administration’s administrative law judge was unconstitutionally appointed under the Appointments Clause, entitling the claimant to a new hearing.

The ruling was part of a nationwide wave of post-Lucia litigation that forced the Social Security Administration to ratify the appointments of its administrative law judges. It reaffirmed claimants' rights to a properly appointed tribunal and significantly influenced the remand and re-adjudication of thousands of disability claims across the United States.