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Clark v. Colvin

United States District Court, District of Columbia

May 11, 2016

Martha L. Clark, Plaintiff,
v.
Carolyn W. Colvin, Acting Commissioner of Social Security, Defendant.

          MEMORANDUM OPINION

          AMIT P. MEHTA United States District Judge

         I. INTRODUCTION

         Section 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.

         In 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.

         The 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 opinion.

         II. BACKGROUND

         A. Factual Background

         1. Plaintiff's First Application for Widow's Insurance Benefits

         Under 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.[1]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.

         Following 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. Id.

         Although 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 criteria-disability.

         2. Plaintiff's Second Application for Widow's Insurance Benefits

         On 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 hearing. Id.

         On 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.

         ALJ Ray 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." Id.

         Plaintiff 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 ...


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