Califano v. Sanders (1977) — Judicial Review of Agency Decisions

Case Identification

Case name: Califano v. Sanders Court: Supreme Court of the United States Year: 1977 Citation: 430 U.S. 99 Claim Presented The respondent sought judicial review of a Social Security Administration determination denying disability insurance benefits. The claim challenged the agency's finding that the respondent was not disabled within the meaning of the Social Security Act.

Authority Cited The Social Security Act, 42 U.S.C. § 405(g) and § 405(h) The Administrative Procedure Act, 5 U.S.C. § 701 et seq. 28 U.S.C. § 1331 (federal question jurisdiction)

Court's Analysis The Court examined whether federal courts possess jurisdiction to review Social Security disability determinations under the Administrative Procedure Act when the Social Security Act's judicial review provisions do not apply. The Court determined that § 405(h) of the Social Security Act channels judicial review exclusively through the mechanism provided in § 405(g), which requires a "final decision of the Secretary made after a hearing." The Court held that where no constitutional claim is presented, the statutory preclusion of review applies. The Court stated that the Administrative Procedure Act does not afford an implied grant of subject-matter jurisdiction permitting federal courts to review agency action. The Court noted that 28 U.S.C. § 1331 provides jurisdiction only where another statute creates a cause of action, and that the APA does not independently create such jurisdiction.

Disposition Judgment of the Court of Appeals reversed. Claim dismissed for want of subject-matter jurisdiction.

Procedural Outcome Judicial review was denied. The agency decision was left undisturbed.

Archival Note This entry documents the judicial record in Califano v. Sanders as preserved in the official reports. The decision addressed statutory limits on judicial review of agency action and clarified that the Administrative Procedure Act does not independently confer subject-matter jurisdiction.