Fourth Circuit Confirms that Even ALJs are Bound by the U.S. Supreme Court

11/09/2011

Workers’ compensation claims filed pursuant to the Longshore & Harbor Workers’ Compensation Act are formally adjudicated by the Office of Administrative Law Judges (ALJ) ALJs are not Article III judges under the judicial branch of the government; rather, they are considered to be part of the executive branch. While it is often true that many procedural rules and rules of evidence are relaxed, Article I judges, and in particular ALJs, do not have the ability or authority to circumvent precedent established by higher Article III courts, including federal circuit courts and the U.S. Supreme Court.

The ALJs got a gentle reminder of this in a recent opinion decided, and published, by the Fourth Circuit. The Fourth Circuit Court of Appeals reversed a decision of the ALJ by finding that BRB committed a clear error of law when it affirmed the ALJ’s decision and order. The Fourth Circuit admonished the ALJ for relying on its own precedent rather than the controlling law set forth by the Supreme Court. In particular, the Fourth Circuit determined that the claimant failed to meet his burden of proof; his claim for binaural hearing loss benefits was denied. Suffice it to say that the Fourth Circuit found the ALJ erred in relying on the decisions of other ALJs in contravention of a previous holding of the Supreme Court.

This case is important beyond any particular hearing loss case. Because of the rather informal nature of the adjudication of claims by Article I judges, from time to time, ALJs drift off course from the establishment of stare decisis, which is the backbone of the legal system. The U.S. Supreme Court is binding precedent on all courts, even Article I administrative law judges. Sometimes they just need a gentle reminder, which was provided quite effectively by the Fourth Circuit this time around.

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