Mathews v. Diaz

In Mathews v. Diaz, 426 U.S. 67 (1976), several plaintiffs challenged the constitutionality of a requirement that only permanent resident aliens who had resided in the United States for at least five years could receive certain Medicare benefits. One of the plaintiffs had joined the civil action before he had actually filed an application for Medicare benefits with the Secretary of the Department of Health, Education, and Welfare. See id. at 75. Subsequently, while the case was pending in the district court, the plaintiff satisfied this condition and moved to supplement his complaint. Id. Although the United States Supreme Court characterized the filing requirement as a "nonwaivable condition of jurisdiction," the Court nevertheless determined that the plaintiff's filing of the application after the pendency of the lawsuit did not divest the district court of jurisdiction. Id. at 75. The Court held that the Secretary's stipulation that the plaintiff's application would be denied was tantamount to a denial of the application and constituted a waiver of the exhaustion requirements of 42 U.S.C. 405(g). Id. at 76. The Court thus interpreted the pleadings as having been impliedly supplemented and permitted the case to continue to a merit-based decision because filing a supplemental complaint was not "too late." Id. at 76. The Court's holding in Diaz was premised on the fact that there was no prejudice to the parties in dealing with the merits because the administrative agency had not yet actually rejected the complainant's claim, which would have caused the statute of limitations to begin running. See id. at 74-78.