United States District Court, District of Columbia
Martha L. Clark, Plaintiff,
Carolyn W. Colvin, Acting Commissioner of Social Security, Defendant.
P. MEHTA United States District Judge
405(h) of the Social Security Act, as codified, provides that
"[t]he findings and decision of the Commissioner of
Social Security after a hearing shall be binding upon all
individuals who were parties to such hearing." 42 U.S.C.
§ 405(h). Federal courts uniformly have held that
Section 405(h) embodies the fundamental principles of res
judicata, which limits relitigation of matters already
decided. This case requires the court to apply those
principles to Defendant Commissioner's denial of
Plaintiff Martha Clark's application for benefits.
1998, Plaintiff submitted her first application for
widow's insurance benefits to the Social Security
Administration (SSA). An administrative law judge (ALJ) found
that she had been married to Postella Young, a recently
deceased District of Columbia resident. The ALJ nevertheless
denied Plaintiff benefits on the ground that she was not
legally disabled, which she was required to show at her age,
51 years old, to qualify for widow's insurance benefits.
Nine years later, at the age of 60, when Plaintiff no longer
had to prove disability, she reapplied. Yet again, the SSA
denied her benefits. This time, contrary to the prior ruling,
a different ALJ found that Plaintiff had not shown that she
had been married to Young. Plaintiff then brought this
lawsuit, asserting that Section 405(h) barred the SSA from
revisiting its twelve-year-old determination that Plaintiff
was the unmarried widow of Young.
court agrees with Plaintiff that the principles of res
judicata embodied in Section 405(h) precluded the SSA
from relitigating Plaintiffs marital status and denying her
widow's benefits for having failed to prove that she had
been married to Young. Accordingly, the court will grant
Plaintiffs Motion for Judgment on the Pleadings, deny
Defendant's Motion for Judgment on the Pleadings, and
remand this case for proceedings consistent with this
Plaintiff's First Application for Widow's Insurance
section 402(e)(1)(B) of the Social Security Act, as codified,
a widow is eligible to obtain her deceased husband's
benefits if she is unmarried and either (1) at least 60 years
old or (2) at least 50 years old and disabled. 42 U.S.C.
§ 402(e)(1)(B). On August 31, 1998, Plaintiff, then 50
years old, filed an application for widow's insurance
benefits, claiming to be the "unmarried widow" of
one Postella Young, who had died in the District of Columbia
on August 2, 1998. Admin. Record [hereinafter AR], ECF No. 7,
at 82, 84.In the same application, Plaintiff also
sought disability benefits and supplemental security income,
which were not contingent upon her status as Young's
widow. Id. at 82. The SSA denied each of
Plaintiff's claims for benefits at the initial review
stage and then again on reconsideration. Id.
Plaintiff timely requested a hearing, which was held before
ALJ John Taggart on December 15, 1999. Id.
a hearing, ALJ Taggart concluded that Plaintiff was
"disabled" within the meaning of the Social
Security Act. Id. at 85, ¶¶ 12-13. He
found that she suffered from "severe alcoholism,
degenerative joint disease, and glaucoma, " id.
¶ 4, which made her unable to "perform more
than a limited range of sedentary work, " id.
¶ 7. Notwithstanding his finding of
"disability, " ALJ Taggart explained that Public
Law 104-121 barred Plaintiff from receiving benefits because
it "prohibits the award of benefits to individuals when
. . . alcoholism is a contributing factor material to a
finding of disability." Id. at 86, ¶¶
14-16. Accordingly, ALJ Taggart denied all three of
Plaintiff's claims-widow's insurance benefits,
disability benefits, and supplemental security income.
ALJ Taggart denied Plaintiff's claims, he made a factual
finding that gives rise to the instant dispute. Under the
heading "Findings of Fact, " ALJ Taggart wrote that
"[t]he claimant is the unmarried widow of the wage
earner who died fully insured on August 2, 1998."
Id. at 84, ¶1; see also Id. at 82
(Plaintiff "is the unmarried widow of the deceased wage
earner[.]"). By describing Plaintiff as Young's
"widow, " ALJ Taggart, at least implicitly, found
that Plaintiff had been married to Young. Plaintiff
nevertheless was deemed ineligible for widow's insurance
benefits because she was less than 60 years old at the time
and had failed to meet the other eligibility
Plaintiff's Second Application for Widow's Insurance
January 16, 2009, eleven years after submitting her first
application for widow's insurance benefits, Plaintiff
submitted a second application at the age of 60. Id.
at 23. The SSA denied Plaintiff's application at the
initial review stage and again upon Plaintiffs request for
reconsideration. Id. Plaintiff timely requested a
November 30, 2012, more than twelve years after ALJ Taggart
had issued his opinion, ALJ Thomas Ray issued a decision
denying Plaintiff's application. He concluded "that
sufficient evidence has not been submitted to establish that
[Plaintiff] and Postella Young entered into a valid
common-law marriage." Id. The ALJ relied on the
lack of evidence corroborating Plaintiff's assertion that
a marriage ceremony had been performed; the absence of any
legal instrument, such as a will, death certificate, or tax
returns, acknowledging that Plaintiff and Young had married;
and the fact that Young apparently was married to someone
else at the time he supposedly married Plaintiff.
Id. at 25.
also rejected Plaintiffs legal contention that the doctrine
of collateral estoppel required him to find that Plaintiff
was the unmarried widow of Postella Young. Id. at
26. ALJ Ray acknowledged that ALJ Taggart earlier had found
that Plaintiff "is the unmarried widow of the deceased
wage earner, Mr. Postella Young, " but determined that
the agency's regulations did not give that finding
preclusive effect. Id. Relying on 20 C.F.R. §
404.950(f), ALJ Ray concluded that he was not required to
apply collateral estoppel unless the applications arose under
different titles of the Social Security Act. Id.
Plaintiff's applications, however, arose under the same
title s of the Act. Id. He also reasoned that §
404.950(f) contains an exception that permits reconsideration
of a prior factual finding if'"there are reasons to
believe that it was wrong.'" Id. (quoting
20 C.F.R. § 404.950(f)). He concluded that, based on
"very little evidence ... to suggest that that claimant
formally married the deceased or that the two held themselves
out as married, " "this case presents reasons to
believe Judge Tagg[a]rt's finding the claimant to be the
unmarried widow of Postella Young is wrong."
appealed ALJ Ray's decision to the SSA's Appeals
Council, which affirmed. Id. at 9. On the issue of
the applicability of collateral estoppel, the Appeals Council
concluded that the doctrine did not apply because "the
hearing decision on which [Plaintiff] seeks to rely was
decided based on a different issue with denial on other
bases." Id. at 11. Describing as
"dicta" ALJ's Taggart's finding that
Plaintiff was Young's "unmarried ...