Heckler v. Campbell

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Facts

The Secretary of the Health and Human Services made a rule which stated that if a claimant suffered from an injury on a given list, then he would get disability without an inquiry. If the injury was less established, the Secretary has to determine if he can do either his former work or other less demanding work. The Secretary has to rely on the age, physical ability, education, and work experience of the claimant. Using these metrics, the Secretary looks up on a medical vocation guideline to figure out if work exists that the claimant can perform. If there is work, then the claimant is not considered disabled.

In this case the plaintiff was injured and the presiding ALJ used the guideline to determine that there was jobs available for her and thus she was not disabled.

Procedural History

The Social Security Appeals Council upheld the ALJ's decision. The District Court for the Eastern District of New York upheld the ALJ's decision. The Court of Appeals for the Second Circuit reversed. The appeals court ruled that the Secretary would have to specifically show jobs that the claimant could work at. The medical-vocational guidelines did not provide the specific evidence that was required.

Issues

  1. Do the guidelines exceed the statutory authority of the SSA?
  2. Are the guidelines arbitrary or capricious?

Discussion

  1. The SSA establishes a scheme that "contemplates that disability hearings will be individualized determinations based on evidence adduced at a hearing." But despite this, a Secretary can use rulemaking to determine issues that do not require case-by-case consideration. In this context, the hearing will determine the specifics of a claimant, and then these specifics will be applied with the guidelines which do not need case-by-case considerations. There is no right for a hearing when the specifics are being applied with the guidelines. No procedures are needed here because the rules were already fleshed out in a rule making process where there was procedure to make sure that the rule picked was fairly.