Califano v. Sanders

In Califano v. Sanders, 430 U.S. 99 (1977), a Social Security claimant filed a claim seeking benefits almost seven years after the Agency had refused an identical claim. An ALJ determined that the second claim was barred by res judicata and also that the claimant did not present the requisite "good cause" for reopening the file. See 20 C.F.R. Sec. 404.988(b). The claimant had never sought judicial review of the denial of his first claim. He did, however, seek judicial review of the ALJ's refusal to consider the merits of his second claim. Ultimately, the Supreme Court determined that it lacked jurisdiction to consider the appeal. The Court recognized Congress' design "to limit judicial review to the original decision denying benefits ... a policy choice obviously designed to forestall repetitive or belated litigation of stale eligibility claims." Califano, 430 U.S. at 108.