A claimant seeking benefits for Social Security Disability ("SSD") is entitled to judicial review of her allegation that the notice denying her claim sent by the Social Security Administration ("SSA") violated her due process rights because her mental impairment did not allow her to understand that she was being given notice. The United States Court of Appeals for the Second Circuit reversed the district court's dismissal of the claimant's due process claim.

In 1974 Theresa Stieberger; who had a long history of mental illness, applied for Supplemental Security Income ("SSI") and SSD. SSA mailed a notice to Stieberger that her applications had been denied, but Stieberger claims to have never received this notice. In 1981 she realized she was not receiving any benefits and filed claims for SSI and SSD which were eventually denied. Stieberger then filed a law suit in federal district court, and after protracted litigation, she eventually won the right to have heating on her failure to appeal firm the denial of her 1974 application. The administrative law judge ("ALJ") filed that she had not shown good cause for missing the deadline, and after unsuccessfully appealing to the Appeals Council, Stieberger sought relief in federal district court.

She asserted a due process claim, alleging that her mental impairment prevented her from receiving proper notice of the 1974 denial. SSA filed a motion to dismiss the action, and the district court judge granted it, holding that the court did not have jurisdiction to address the substance of the ALJ's decision, only to ensure she received a proper hearing. The court found that Stieberger's constitutional claim essentially asked that she be heard again on the substance of her 1974 claim.

Stieberger appealed, and the Second Circuit reversed. The court held that Stieberger presented evidence that she had been mentally ill since 1967, and that in 1974 she was diagnosed as suffering firm schizophrenia. As a result, she had made a "particularized allegation of mental impairment" preventing her from understanding the notice given to her; and thus had satisfied the heightened standard required to assert a due process claim. The court remanded the ease to the district court to determine, after giving both parties the opportunity to be heard, whether or not the ALJ's decision was "supported by substantial evidence."