KOZINSKI, Circuit Judge:
Rolen applied for Social Security disability benefits in 1991, claiming that he had been disabled since 1989. The Administrative Law Judge dismissed his application on procedural grounds. A notice accompanying the dismissal order advised Rolen that "[i]f you disagree with the enclosed order of dismissal, you have the right to appeal." The notice did not advise Rolen that he could file a new application.
Four years later, Rolen filed...
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