Sims v. Apfel

530 U.S. 103 (2000)

Facts

P filed applications for disability benefits under Title II of the Social Security Act. P alleged disability from a variety of ailments, including degenerative joint diseases and carpal tunnel syndrome. After a state agency denied her claims, she obtained a hearing before a Social Security ALJ. The ALJ also denied her claims, concluding that, although she did have some medical impairments, she had not been and was not under a 'disability,' as defined in the Act. P then requested that the Social Security Appeals Council review her claims. P, through counsel, submitted a letter arguing that the ALJ had erred in several ways in analyzing the evidence. The Council denied review. P filed suit in the District Court stating three reasons. The District Court rejected all of these contentions. The Court of Appeals affirmed on the merits with regard to P's first contention. With regard to the second and third contentions, it concluded that it lacked jurisdiction because P had not raised those contentions in her request for review by the Appeals Council. The Supreme Court granted certiorari.