Haddock v. Commissioner of Social Security, 1:20-cv-01064

Pro se plaintiff John Haddock filed a Social Security appeal on February 25, 2020, alleging entitlement to disability benefits beginning upon his release from prison on October 4, 2019.
Plaintiff used the Social Security appeal form but did not allege he filed an application for benefits or that the Social Security Administration issued a final decision; he wrote "don't remember" or "don't know" for hearing and denial dates.
The complaint contains no SSA documents, no allegation of a final decision under 42 U.S.C. § 405(g), and no argument that exhaustion should be waived or excused.
The court reviewed subject-matter jurisdiction sua sponte and concluded the jurisdictional requirement of a final administrative decision had not been met.
The court granted Haddock in forma pauperis status for filing, dismissed the complaint without prejudice for lack of subject-matter jurisdiction, and instructed Haddock to pursue an SSA application and, after a final decision, to file a new suit if dissatisfied.
The court certified that any appeal would not be taken in good faith and denied in forma pauperis status for appeal; it directed entry of judgment and closure of the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal court has jurisdiction to hear a Social Security appeal absent a final decision from the Commissioner and exhaustion of administrative remedies	Haddock asserts entitlement to benefits beginning Oct 4, 2019 and purports to appeal an ALJ decision (but provides no dates or evidence of application/decision)	No final administrative decision or exhaustion; jurisdiction under §405(g) unmet	Dismissed without prejudice for lack of subject-matter jurisdiction because plaintiff failed to allege or show a final decision/exhaustion
Whether failure to exhaust can be excused or waived	Plaintiff did not plead facts arguing waiver or excuse	No basis alleged to waive or excuse exhaustion	Court noted waiver/excuse not asserted and did not excuse exhaustion

FDIC v. Four Star Holding Co., 178 F.3d 97 (2d Cir. 1999) (district court may examine subject-matter jurisdiction sua sponte)
City of New York v. Heckler, 742 F.2d 729 (2d Cir. 1984) (discussing circumstances in which exhaustion requirement may be waived)
Pavano v. Shalala, 95 F.3d 147 (2d Cir. 1996) (discussing when failure to exhaust administrative remedies may be excused)
Coppedge v. United States, 369 U.S. 438 (1962) (standard for determining whether an appeal is taken in good faith for IFP purposes)