Karen Dexter v. Carolyn W. Colvin

Ten years ago, Karen Dexter first applied for social security disability insurance benefits. After benefits were denied, Dexter requested a hearing. The Social Security Administration (“SSA”) ruled her request untimely, and denied a subsequent application on the ground of res judicata, but it has never explained why it rejected Dexter’s facially valid excuse for the delay in her hearing request. Dexter then sought review in federal district court, which dismissed her action for lack of subject matter jurisdiction. Because the administrative law judge (“ALJ”) failed to consider whether her facially valid reasons constituted good cause excusing the delay, thus depriving Dexter of her due process right to a meaningful opportunity to be heard and to seek reconsideration of an adverse benefits determination, we reverse and remand for further proceedings.

I.

A

The administrative review process governing applications for social security benefits “consists of several steps, which usually must be requested within certain time periods and in [a particular] order.” 20 C.F.R. § 404.900 (a). If a dissatisfied applicant fails to take the next step within the stated time period, the…