Roderick Johnson v. Social Security Administration, et al.

Summary

The United States District Court for the District of Maryland denied Plaintiff Roderick Johnson's motion for summary judgment and granted Defendants' motion to dismiss or, alternatively, for summary judgment. The court held that no viable Bivens remedy was available against the individual Social Security employee and that sovereign immunity and the Social Security Act's jurisdictional provisions barred constitutional claims against the Social Security Administration. The court further held that Johnson had not exhausted the Social Security Administration's administrative review process and therefore dismissed the action and closed the case.

Holdings

1. Plaintiff could not maintain a Bivens action against Ms. Betts because the alleged withholding of Social Security benefits presented a new context outside the three recognized Bivens contexts, and Congress was better equipped to determine whether a damages remedy should exist.
2. Plaintiff could not assert constitutional claims against the SSA because the United States and its agencies are immune from suit absent a waiver, and the Social Security Act provides the applicable limited waiver and exclusive route for review of claims arising under the Act.
3. The court lacked subject matter jurisdiction because Plaintiff had not received a final decision from the Commissioner and had not exhausted the SSA's four-step administrative review process.

Questions Presented

1. Whether Plaintiff could maintain a Bivens constitutional damages claim against the federal employee concerning the withholding of Social Security benefits.
2. Whether the United States and the SSA were subject to Plaintiff's constitutional claims despite sovereign immunity and the Social Security Act's channeling of judicial review through 42 U.S.C. § 405(g).
3. Whether the court had subject matter jurisdiction under 42 U.S.C. § 405(g) where Plaintiff had not obtained a final decision from the Commissioner or exhausted the SSA's administrative review process.
4. Whether Plaintiff was entitled to summary judgment.

Disposition

dismissed