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Rita Arguijo Garcia v. Commissioner of Social Security
23-14073
11th Cir.
Apr 14, 2025
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Background

  • 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)
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Case Details

Case Name: Rita Arguijo Garcia v. Commissioner of Social Security
Court Name: Court of Appeals for the Eleventh Circuit
Date Published: Apr 14, 2025
Docket Number: 23-14073
Court Abbreviation: 11th Cir.