Rational Basis Upheld for SSA Ruling 11-1p’s Protective Filing Date Under Fifth Amendment

Introduction

In Rita Arguijo Garcia v. Commissioner of Social Security, the Eleventh Circuit addressed whether Social Security Ruling 11-1p (“SSR 11-1p”)—which governs when a claimant may receive a “protective filing date” on a subsequent request for review—violates the Fifth Amendment’s guarantee of equal protection. Rita Arguijo Garcia, having applied for disability benefits on December 31, 2019, was found “not disabled” by an Administrative Law Judge and denied review by the Appeals Council, which refused to assign an earlier protective filing date when her attorney later submitted age-related evidence. She challenged SSR 11-1p as an unconstitutional classification that advantages certain claimants over others. The Court, relying principally on rational basis review and the prior panel decision in Williams v. Commissioner of Social Security, affirmed the district court’s order upholding the SSA ruling.

Summary of the Judgment

The Court of Appeals unanimously affirmed the denial of benefits and rejected the equal protection challenge to SSR 11-1p. It held:

SSR 11-1p does not create a suspect classification or impair a fundamental right; only rational‐basis scrutiny applies.
SSR 11-1p’s distinction—granting a protective filing date to claimants who submit new (even chronologically irrelevant) evidence but not to those who submit no evidence—serves legitimate government objectives.
Those objectives include preventing conflicting decisions, avoiding duplication of proceedings, and reducing administrative burdens and improper payments.
Because there exists a conceivable rational relationship between SSR 11-1p’s disparate treatment and these objectives, the rule survives constitutional scrutiny.

Analysis

Precedents Cited

SSR 11-1p (76 Fed. Reg. 45309–03): Revised SSA procedures in 2011 to limit simultaneous pending claims and set out protective filing date rules.
Washington v. Social Security Admin., 806 F.3d 1317 (11th Cir. 2015): Confirmed claimants may submit new evidence post-ALJ hearing even under restrictive procedures.
Williams v. Commissioner, No. 21-10920, 2022 WL 791711 (11th Cir. Mar. 16, 2022): Held SSR 11-1p’s treatment rationally related to administrative efficiency and fairness, rejecting an equal protection challenge under almost identical facts.
Weinberger v. Wiesenfeld, 420 U.S. 636 (1975): Established that due process in the Fifth Amendment incorporates an equal protection component.
Sessions v. Morales-Santana, 582 U.S. 47 (2017): Clarified rational basis standard for equal protection under the Fifth Amendment.
Leib v. Hillsborough County Pub. Transp. Comm’n, 558 F.3d 1301 (11th Cir. 2009): Plaintiff bears the burden of negating every conceivable rational basis for a classification.
Eknes-Tucker v. Governor of Ala., 80 F.4th 1203 (11th Cir. 2023) (en banc): Emphasized deference under rational basis review.

Legal Reasoning

1. Standard of Review: Because SSR 11-1p does not implicate a suspect class or fundamental right, the Eleventh Circuit applied rational basis review to Ms. Arguijo Garcia’s equal protection challenge.

2. Legitimate Government Purpose: The SSA identified three interrelated objectives: (a) avoiding simultaneous appeals and new applications that could produce inconsistent outcomes; (b) preventing improper benefit payments; and (c) reducing administrative costs and redundancies.

3. Rational Connection: SSR 11-1p’s mechanism for awarding a protective filing date to claimants who submit any new evidence—regardless of chronological relevance—ensures that bona fide new applications are not penalized due to uncertainty about when evidence arose. Granting the date in borderline cases preserves claimants’ rights while streamlining agency processes.

4. Failure to Negate All Rational Bases: The claimant did not disprove all conceivable reasons—such as administrative convenience and consistency concerns—that could justify treating different groups of claimants differently. Under Leib, this dooms her challenge.

Impact

The decision reaffirms the judiciary’s long-standing deference to Social Security procedural rules under rational basis review. It provides guidance to future litigants that:

Challenges to SSA’s procedural rulings—even when they produce uneven results—face a steep hurdle unless a suspect classification or fundamental right is implicated.
Agencies may adopt bright-line rules to preserve consistency and administrative efficiency, provided there is a conceivable rational link to legitimate objectives.
Claimants uncertain about the chronological relevance of their evidence should still submit it to preserve a protective filing date.

Complex Concepts Simplified

Protective Filing Date: The date SSA treats as the effective filing date of a new claim—often earlier than when the formal application is received—when a claimant submits new evidence after an ALJ decision.
Rational Basis Review: The most deferential constitutional test. A law or regulation survives if it is “rationally related” to any “legitimate government purpose.”
Equal Protection (Fifth Amendment): The Fifth Amendment’s Due Process Clause protects against discriminatory federal action in the same manner the Fourteenth Amendment applies to states.
Suspect Classification: A grouping (e.g., race, religion) that triggers strict scrutiny. Age and procedural status are not suspect classes.

Conclusion

In Arguijo Garcia, the Eleventh Circuit solidified the principle that SSA procedural rules like SSR 11-1p need only a rational basis when challenged on equal protection grounds. The ruling underscores the agency’s latitude to craft bright-line procedures that streamline decision-making and prevent inconsistent outcomes, while still safeguarding claimants’ substantive rights through protective filing dates. As a result, SSR 11-1p remains in force, and future litigants must identify either a suspect classification or a fundamental right deprivation to overcome similar challenges.