Monet v. Colvin
Civil Action No. 2016-2040
| D.D.C. | Jul 25, 2017Background
- Monet sought review of an SSA August 1, 2006 determination that she had been overpaid more than $13,000 in disability benefits because she allegedly was confined after being found incompetent to stand trial, which disqualifies benefits under 42 U.S.C. § 402(x).
- After the Overpayment Determination, Monet’s representative obtained an ALJ hearing; in March 2008 the ALJ issued a “fully favorable” decision waiving recovery of the overpayment as Monet was found “without fault.”
- Monet contends she never learned of that ALJ proceeding or its favorable ruling until 2017, and maintains no court ordered commitment occurred during the period at issue; she seeks correction of the factual record and to pursue appeal.
- The SSA (Acting Commissioner Berryhill) moved to dismiss for lack of subject-matter jurisdiction, asserting Monet lacks a cognizable injury and has not exhausted administrative remedies.
- Monet also filed a separate motion to remand to the SSA Appeals Council, noting she has a pending Request for Reconsideration and asking the court to remand for development of evidence about alleged court-ordered commitment.
- The district court dismissed the complaint for lack of Article III standing and for failure to exhaust administrative remedies, and denied Monet’s remand request; the court also rejected Monet’s claim that exhaustion should be waived.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III standing | Monet says correcting ALJ's factual error causes injury and allows review | Berryhill says Monet has no concrete injury: SSA neither owes benefits nor is seeking recovery | Dismissed for lack of standing; mere correction of record is not concrete injury (Spokeo) |
| Exhaustion of administrative remedies | Monet argues timely notice failure waived exhaustion; asks remand to develop evidence | Berryhill says Monet has not exhausted appeals and has pending Request for Reconsideration; exhaustion required | Dismissed for failure to exhaust; court declines to waive exhaustion because not futile (Ryan) |
| Validity of ALJ’s prior favorable decision | Monet contends ALJ reached result on incorrect facts and legal conclusions and should be revisit-able | Berryhill relies on ALJ’s fully favorable decision and ongoing administrative procedures | Court did not disturb ALJ decision; substantive challenge requires exhaustion and standing; not adjudicated on merits |
| Request to remand to Appeals Council | Monet asks remand to take evidence re: institutional confinement | Berryhill opposes federal intervention before administrative process completes | Remand denied because plaintiff must exhaust administrative remedies first |
Key Cases Cited
- Arpaio v. Obama, 797 F.3d 11 (D.C. Cir.) (standing analysis under Article III)
- Carpenters Indus. Council v. Zinke, 854 F.3d 1 (D.C. Cir.) (even minimal economic harm can establish injury-in-fact)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (U.S.) (statutory violations require a concrete injury to confer standing)
- Ryan v. Bentsen, 12 F.3d 245 (D.C. Cir.) (administrative exhaustion requirements for SSA review)