Heckler v. Campbell, 461 U.S. 458 (1983)
FACTS: The original case, Heckler v. Campbell was heard in 1983 by the US Supreme Court. It was the certiorari to the United States Court of Appeals for the Second Circuit. Heckler, the Secretary of Health and Human services was the petitioner, while Campbell was respondent. It is known that in 1979, Carmen Campbell of 52 year old applied for her social disability benefits because she had bad health condition (backache and hypertension) which prevented her from performing her working duties as a hotel maid in a proper way. However, her application was denied by the Court and she insisted on the hearing de novo before an Administrative Law Judge. He came to the conclusion that her health problem was not severe enough to consider Campbell disabled and that she could perform some less strenuous job. Campbell had a limited education. She was born in Panama and had difficulties in speaking and writing English.
However, she could understand and read English rather well. Taking into consideration the medical-vocational guidelines, the Administrative Law Judge stated that a great number of light jobs could be performed by Campbell, because she was not disabled. The Court of Appeal, the Second Circuit reversed because the Health and Human Services guidelines were absolutely inadequate as “evidence of a claimant’s ability to perform a specific alternative occupation.” However, Heckler who was the Petitioner in this case stated that the Court of Appeals’ holding effectively prevented her use of the medical-vocational guidelines by requiring Campbell to define some specific jobs in every disability hearing. In this case, the US Supreme Court granted certiorari.
ISSUES: The major issue of this case is based on the fact that the Secretary of Health and Human Services relied on medical-vocational guidelines in order to determine a claimant’s right to social security disability benefits.
SOLUTIONS: According to the opinion of Justice Powell, the US Supreme Court reversed the Second Circuit, stating that “where 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 US Supreme Court concluded that the agency, namely the Health and Human services, could fully rely on its authority to determine those issues that didn’t require case-by-case considerations. Moreover, the court asserted that the Secretary’s reliance on the guidelines were not inconsistent with the Social Security Act and they were not arbitrary and capricious.
REASONS: The major reasons are connected with the Social Security Act which guarantees social security benefits to different categories of the US citizens including the disabled people and old aged people. The Judge Powell stated that the Social Security Act directed Heckler, the Secretary of Health and Human Services, to adopt appropriate rules and regulations in order to provide the proofs, evidence in that disability case. He also concluded that disability hearings should be individualized determinations and should be based on evidence.
Clifton Sykes v. Kenneth Apfel, 228 F.3d 259 (2002)
FACTS: The original case, Clifton Sykes v. Kenneth Apfel was heard in 2000 by the US Court of Appeals for the Third Circuit. Clifton Sykes was an appellant, and Kenneth Apfel, the Commissioner of Social Security, was an appellee. It is known that Clifton Sykes got some serious job-related injuries which prevent him to perform his duties at work in a proper way. He filed for social security benefits connected with his disability to work. However, Social Security Administration concluded that Sykes was not disabled according to the Social Security Act. Sykes requested to hold a hearing before the Administrative Law Judge who stated that Sykes had got some severe impairment, such as left-eye blindness and others. However, under the regulations, he considered them to be non-exertional impairments and denied Sykes’s application. Moreover, using medical-vocational guidelines “as a framework” and without addressing to any vocational expert, the Commissioner concluded that Sykes’s exertional impairments allow him to perform some kind of light work, and that it is necessary for him to exclude those jobs which require binocular vision. The denial of the Social Security Administration became a final decision. Then, the Social Security Administration Appeals Council also denied Sykes’s request to review that decision. It is known that Sykes worked for about twenty years as a tractor-trailer operator. This work was physically strenuous for him and required to load seventy-eighty pounds of goods. During his employment, Sykes suffered several injuries including arm injury, shoulder injury and his left eye injury which left him permanently blinded in his left eye. So, Sykes decided to file a complaint in the United States District Court for the District of New Jersey in order to review of the decision of Administrative Law Judge.
ISSUES: The major issue in this case is based on the fact that the Administrative Law Judge relied exclusively on the medical-vocational guidelines or grids in assessing whether there were jobs in the national economy exertional and non-exertional.
SOLUTIONS: The Court of Appeals agreed that the medical-vocational guidelines or grids cannot automatically establish the fact that there are jobs in the national economy when a claimant has severe exertional and non-exertional impairments. The Court concluded that the Commissioner cannot establish the fact that there are jobs in the national economy that such person as Sykes has an opportunity to perform in a proper way relying only on the medical-vocational guidelines or grids. The judgment was reversed. The US Court of Appeal rejected Sykes’s claim that the Social Security Administration failed to accept the Court’s prior decisions.
REASONS: According to the Social Security Act, the claimant has his right to receive disability benefits if his physical or mental impairments are of such severity that he cannot do his previous work as well as he cannot be engaged in any other kind of work which exists in the national economy. In this case, it is necessary to take into consideration his age, education, and work experience. Moreover, the Social Security Act states that disability determinations should be individualized and should be based on the evidence represented at a hearing. The Social Security Act also provides the Social Security Administration with authority to develop regulations in order to implement these provisions.
Richardson v. Perales, 402 U.S. 389 (1971)
FACTS: The original case, Richardson v. Perales was heard in 1971 by the US Supreme Court. Richardson, the Secretary of health, Education and Welfare was a petitioner in this case. It is known that in 1966, Pedro Perales, a truck driver who was 34, filed a claim for receiving disability insurance benefits under the Social Security Act. In his claim, Perales asserted that in 1965, he got a serious back injury when he was lifting some object at work and became disabled. The neurosurgeon, Dr. Ralph A. Munslow, examined him and recommended conservative treatment. He performed myelography and surgery for a possible protruded intervertebral disc at L-5. The patient hesitated about surgery operation, but soon he gave consent to the recommended medical procedure. He was operated by Dr. Munslow. The procedure showed that there was no disc protrusion or any other definitive pathology. The final diagnosis was the following “Neuritis, lumbar, mild.” The State Division of Disability Determination denied satisfying Perales’ claim for receiving disability benefits.
ISSUES: The major issue in this case is whether physicians’ written reports concerning medical examinations of a disability claimants may constitute the so-called “substantial evidence” to support a finding of non-disability, within the 205 (g) standard, when the claimant makes objection to the admissibility of the above mentioned reports and when the only live evidence is presented by his side and contradicts the physicians’ reports.
SOLUTIONS: The US Supreme Court held that the physicians’ interpretation of the medical data was the evidence in an agency hearing. Justice Douglas, Justice Black and Justice Brennan proved that all written reports of physicians who examined the claimant for his disability insurance benefits under the Social Security Act constitute the so-called “substantial evidence” and support a non-disability finding according to standard of 205 (g) of the Act. The procedure which was followed under Act does not violate due process requirements.
REASONS: The major reasons of the Court’s decision are based on the Social Security Act and Administrative Procedure Act. The Court’s decision proved that the medical material may be substantial evidence when this medical material stands alone and is opposed by live medical evidence and the client’s own contrary personal testimony.