Dobbs v. Social Security Administration, Commissioner

Dobbs applied for Social Security disability benefits. An administrative law judge (ALJ) denied the claim, and the Appeals Council upheld the decision. Dobbs then filed suit in federal district court, arguing for the first time that the ALJ’s appointment violated the Appointments Clause of the U.S. Constitution and requesting a new hearing. The district court dismissed the challenge, ruling that Dobbs had forfeited the issue by failing to raise it during the administrative proceedings. The Tenth Circuit affirmed, holding that claimants must timely present Appointments Clause objections to the agency. The court relied on the Supreme Court’s recent decision in Lucia v. SEC, which addressed similar challenges but did not excuse the failure to exhaust administrative remedies.

The United States Court of Appeals for the Tenth Circuit affirmed the district court’s dismissal, holding that the plaintiff forfeited the Appointments Clause challenge by not presenting it to the Social Security Administration.

Whether a Social Security disability claimant waives the right to challenge the constitutionality of an administrative law judge's appointment by failing to raise the issue during the agency's administrative proceedings.

The ruling reinforced the requirement to exhaust administrative remedies in Social Security cases, effectively limiting retroactive challenges to ALJ appointments after Lucia. It prompted claimants to raise any constitutional objections at the earliest stage of agency adjudication.