Heckler v. Campbell

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1983 United States Supreme Court case

Heckler v. Campbell, 461 U.S. 458 (1983), is a United States Supreme Court case concerning whether the United States Secretary of Health and Human Services could rely on published medical-vocational guidelines to determine a claimant’s right to Social Security benefits.[1] [2]

Background

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In 1978, the Secretary of Health and Human Services promulgated regulations in order to implement the statutory definition of disability . People who were disabled were separated into two groups: those who could not perform any gainful work and those with less severe impairments. For this second group, the Secretary promulgated guidelines to examine whether the claimant could perform either their former work or some less demanding employment by creating a matrix that evaluated four factors that had been identified by Congress : physical ability, age, education, and work experience. Information was also compiled about what jobs were available.[3]

Carmen Campbell claimed she had a back condition that kept her from working at her former job as a hotel maid . Ms. Campbell had been born in Panama , and though she had limited ability to speak and write English , she could read and understand English to a fair degree. The administrative law judge in her case found that by using the guidelines, there were a significant number of jobs that existed that Ms. Campbell could perform and concluded that she was not disabled.

Ms. Campbell's case was appealed to the United States Court of Appeals for the Second Circuit which reversed the decision, saying that the guidelines did not provide evidence that specific alternative jobs existed, and that the determination that Ms. Campbell was not disabled was not supported by substantial evidence as required by the Social Security Act .

Opinion of the Court

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In an opinion delivered by Justice Powell , the Supreme Court reversed the Second Circuit, saying that “[w]here the statute expressly entrusts the Secretary with the responsibility for implementing a provision by regulation, review is limited to determining whether the regulations promulgated exceeded the Secretary’s statutory authority and whether they are arbitrary and capricious.” The Court decided that even where an agency's enabling statute expressly required that it hold a hearing, the agency could rely on its rulemaking authority to determine issues that didn't require case-by-case considerations.

The Court held that the Secretary’s reliance on the guidelines was not inconsistent with the Social Security Act , nor were the guidelines arbitrary and capricious.

Justice Brennan concurred while pointing out that the record contained scant evidence about Ms. Campbell's ability to do "light work."

Justice Marshall dissented essentially on the same grounds.

References

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↑ Social Security Bulletin . Social Security Board. 1985. p. 31.
↑ Smith, Mark S. (1984). "Heckler v. Campbell and the Grid: Are Disability Claimants Entitled to Examples of Suitable Jobs?" . American Journal of Law & Medicine. 9 (4): 501–515. doi :10.1017/S0098858800009230 . ISSN 0098-8588 . PMID 6486123 . S2CID 23691168 .
↑ Dubin, Jon C. (2010). "Overcoming Gridlock: "Campbell" After a Quarter-Century and Bureaucratically Rational Gap-Filling in Mass Justice Adjudication in the Social Security Administration's Disability Programs" . Administrative Law Review. 62 (4): 937–1010. ISSN 0001-8368 . JSTOR 25758557 .

External links

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Text of Heckler v. Campbell, 461 U.S. 458 (1983) is available from: Internet Archive (docket files) Justia Library of Congress Oyez (oral argument audio)

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How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

noting that the Act requires individualized determination based on evidence adduced at a hearing

describing role of vocational expert as determining whether jobs existed in the national economy that the claimant could perform

sustaining the Grid as a way to make this process more uniform

discussing considerations and noting the “need for efficiency” in considering disability claims