Charles Talley, Jr. v. Frank Bisignano, Commissioner of Social Security Administration1

24-2431Court of Appeals for the Eighth Circuit31 oct. 2025

Texte intégral

United States Court of Appeals
For the Eighth Circuit
___________________________
No. 25-1445
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Charles Talley, Jr.
lllllllllllllllllllllPlaintiff - Appellant
v.
Frank Bisignano, Commissioner of Social Security Administration1
lllllllllllllllllllllDefendant - Appellee
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Appeal from United States District Court
for the Southern District of Iowa - Eastern
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Submitted: October 14, 2025
Filed: October 17, 2025
[Unpublished]
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Before LOKEN, BENTON, and KOBES, Circuit Judges.
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1Frank Bisignano has been appointed to serve as Commissioner of Social
Security, and is substituted as appellee pursuant to Federal Rule of Appellate
Procedure 43(c).

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PER CURIAM.
Charles Talley, Jr. appeals the district court’s2 order, which affirmed the
decision of the Commissioner of the Social Security Administration regarding the
amount of his retirement insurance benefit payments, found that it lacked jurisdiction
over his dispute regarding overpaid supplemental security income (SSI) benefits, and
found that his constitutional claims failed. We affirm.
After careful review of the record and the parties’ arguments on appeal, we
agree that substantial evidence supported the decision of the administrative law judge
regarding Talley’s retirement insurance benefit payment amount. See Lucus v. Saul,
960 F.3d 1066, 1068 (8th Cir. 2020) (de novo review of district court’s decision
upholding denial of Social Security claim; Commissioner’s decision will be upheld
if it complies with relevant legal standards and is supported by substantial evidence
in record as whole). We also agree that the district court lacked subject matter
jurisdiction over Talley’s claim regarding his SSI overpayments, see Abdurrahman
v. Dayton, 903 F.3d 813, 816 (8th Cir. 2018) (de novo review of mootness dismissal);
Sipp v. Astrue, 641 F.3d 975, 979 (8th Cir. 2011) (de novo review of dismissal for
lack of subject matter jurisdiction based on failure to exhaust administrative
remedies); and that Talley did not allege sufficient facts to state a constitutional
claim, see Reutter ex rel. Reutter v. Barnhart, 372 F.3d 946, 950 (8th Cir. 2004) (de
novo review of constitutional claims raised in conjunction with Social Security
appeals). We find no abuse of discretion in the district court’s implicit denial of
Talley’s request to amend the complaint, made in a sentence at the end of his reply
brief. See Misischia v. St. John’s Mercy Health Sys., 457 F.3d 800, 805 (8th Cir.
2006).
2The Honorable Stephanie M. Rose, Chief Judge, United States District Court
for the Southern District of Iowa.
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The judgment is affirmed.
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