Rita Arguijo Garcia v. Commissioner of Social Security
23-14073
11th Cir.Apr 14, 2025Background
- Rita Arguijo Garcia applied for Social Security disability benefits, alleging she was unable to work due to disability.
- Her application was denied by an administrative law judge (ALJ), and this was affirmed on appeal by the Appeals Council.
- Garcia contested the lack of a “protective filing date”—a procedural benefit provided in some cases when claimants submit new but irrelevant evidence to the Appeals Council under SSR 11-1p.
- She argued in district court that the regulation (SSR 11-1p) violates the Fifth Amendment's equal protection guarantee because it treats some claimants more favorably based on the type of evidence submitted.
- The district court affirmed the Commissioner’s denial; Garcia appealed to the Eleventh Circuit.
- The main issue on appeal relates to whether SSR 11-1p’s procedures violate equal protection under the Fifth Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of SSR 11-1p under Fifth Amendment | SSR 11-1p denies equal protection by treating claimants differently based on evidence submitted for review. | Regulation has a rational basis; disparate treatment is justified by administrative needs and fairness. | No violation; court affirms constitutionality. |
Key Cases Cited
- Weinberger v. Wiesenfeld, 420 U.S. 636 (1975) (establishing that the Fifth Amendment’s due process clause imposes equal protection requirements on the federal government)
- Sessions v. Morales-Santana, 582 U.S. 47 (2017) (clarifying rational basis review for classifications not implicating suspect classes or fundamental rights)
- Leib v. Hillsborough Cnty. Pub. Transp. Comm’n, 558 F.3d 1301 (11th Cir. 2009) (sets forth rational basis requirement for equal protection claims)
- Crayton v. Callahan, 120 F.3d 1217 (11th Cir. 1997) (standards for reviewing constitutional challenges to administrative regulations)
- Henry v. Comm’r of Soc. Sec., 802 F.3d 1264 (11th Cir. 2015) (de novo review of the application of legal principles by an ALJ)
