Carr v. Saul, 593 U.S. 83

Six claimants applied for Social Security disability benefits; each was denied at initial review, before an SSA ALJ, and by the Appeals Council.
After Lucia v. SEC, which held SEC ALJs were unconstitutionally appointed, claimants argued SSA ALJs were likewise improperly appointed and sought new hearings before constitutionally appointed ALJs.
The SSA ratified ALJ appointments and issued limited relief: fresh review only for claimants who had raised Appointments Clause objections during administrative proceedings.
Petitioners had not raised such objections administratively and therefore sought relief in federal court; the Eighth and Tenth Circuits held the claims forfeited.
The Supreme Court granted certiorari to resolve a circuit split and held that petitioners did not forfeit their Appointments Clause claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a judicially created issue-exhaustion rule requires raising Appointments Clause claims before SSA ALJs	Petitioners: No judicial exhaustion required because SSA proceedings are nonadversarial and no statute/regulation imposed such a rule	Saul: Courts should impose exhaustion by analogy to adversarial litigation to preserve administrative authority and efficiency	Court: No; courts erred in imposing an issue-exhaustion requirement here because SSA proceedings are largely inquisitorial and Sims controls
Whether Appointments Clause claims are subject to exhaustion given they are structural constitutional claims	Petitioners: Constitutional claims fall into an exception; ALJs lack authority/expertise to decide such structural questions	Saul: Petitioners should have raised the issue to allow agency correction and policy change	Court: Exception applies — structural constitutional claims and futility of agency remedy counsel against exhaustion
Whether petitioners’ challenges were untimely under doctrines like "timely challenge" in Ryder/Lucia	Saul: Challenges were untimely and forfeited if not raised earlier	Petitioners: Ryder/Lucia arose in different, adversarial contexts and do not define timeliness for SSA’s scheme	Court: Commissioner failed to show challenges were untimely; Ryder/Lucia do not dictate timeliness here

Sims v. Apfel, 530 U.S. 103 (explaining issue-exhaustion analysis for SSA and difference between adversarial and inquisitorial proceedings)
United States v. L. A. Tucker Truck Lines, Inc., 344 U.S. 33 (general rule favoring timely administrative objections in adversarial agency proceedings)
Free Enterprise Fund v. Public Co. Accounting Oversight Bd., 561 U.S. 477 (structural constitutional challenges fall outside agency expertise)
Bethesda Hosp. Assn. v. Bowen, 485 U.S. 399 (recognizing futility exception to exhaustion)
Ryder v. United States, 515 U.S. 177 (discussing timeliness in military/court-martial context)
Mathews v. Eldridge, 424 U.S. 319 (constitutional claims may be raised in court after exhausting administrative process)
McCarthy v. Madigan, 503 U.S. 140 (exhaustion inquiry requires examining characteristics of particular administrative procedure)
Richardson v. Perales, 402 U.S. 389 (procedural due process claim where claimant failed to use available administrative procedures)
Lucia v. S.E.C., 585 U.S. _ (holding SEC ALJs were officers under the Appointments Clause)