Court Opinion: 10th Circuit Court of Appeals Opinion for March 27

The 10th Circuit Court of Appeals

Editor’s Note: Law Week Colorado edits court opinion summaries for style and, when necessary, length.

Czajkowski v. Commissioner, SSA


In April 2023, Conrad Czajkowski filed a complaint for review of a social security disability benefits decision with the U.S. District Court for the District of Colorado. 

According to the opinion, his initial complaint didn’t utilize the district court’s approved complaint form and his second amended complaint was incomplete. In June 2023, the court directed Czajkowski to cure the filing deficiencies, reminded him he needed to provide a copy of the Social Security Administration’s final decision regarding his claim and ordered him to show cause why his case shouldn’t be dismissed for lack of subject-matter jurisdiction. Czajkowski filed a third amended complaint but didn’t attach a copy of the final agency decision. He didn’t respond to the show-cause order.

Czajkowski alleged he was approved to receive $797 per month in social security disability insurance benefits beginning in June 2022. The first benefits payment was deposited in his bank account on June 8, 2022. However, on July 13, 2022, he attempted to access the second benefits payment and found it hadn’t been deposited. He called an SSA office in Washington, D.C. about the missing payment and was informed it should’ve been deposited.

Later that day, Czajkowski was arrested for a parole violation, and he has been detained since that time. Czajkowski asserts he hasn’t violated any condition of his parole or been convicted of a crime that would result in parole revocation. He has written to multiple SSA offices, the opinion noted, inquiring about the missing disability insurance benefits, with no response. He hasn’t received a decision from the SSA suspending or terminating his benefits.

For relief, Czajkowski asked the district court to order the SSA commissioner to pay him disability insurance benefits dating back to July 2022. The district court dismissed Czajkowski’s third amended complaint without prejudice, explaining without a final agency decision it lacked subject-matter jurisdiction under 42 U.S. Code 405(g). Czajkowski timely appealed.

The 10th Circuit Court of Appeals affirmed the district court’s judgment dismissing Czajkowski’s amended complaint and granted his motion for leave to proceed without prepayment of costs and fees.

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