Law School Case Brief
Barnhart v. Walton - 535 U.S. 212, 122 S. Ct. 1265 (2002)
The Social Security Act authorizes payment of disability insurance benefits and Supplemental Security Income to individuals with disabilities. 42 U.S.C.S. § 401 et seq.; 42 U.S.C.S. § 1381 et seq. For both types of benefits the Act defines the key term "disability" as an inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.
The Social Security Act authorized payment of Title II disability insurance benefits and Title XVI Supplemental Security Income to individuals who have an "inability to engage in any substantial gainful activity by reason of any medically determinable . . . impairment . . . which has lasted or can be expected to last for a continuous period of not less than 12 months." The Social Security Administration (Agency) denied benefits to respondent Walton, finding that his "inability" to engage in substantial gainful activity lasted only 11 months. The District Court affirmed, but the Fourth Circuit reversed, holding that the 12-month duration requirement modified "impairment" not "inability." Moreover, the Fourth Circuit held that the statute left no doubt that no similar duration requirement relates to an "inability," and that therefore Walton was entitled to benefits despite Agency regulations restricting them to those unable to work for 12 months. The court decided further that Walton qualified for benefits because, prior to his return to work, his "inability" would have been "expected" to last 12 months. The Court granted the government’s petition for certiorari.
Was the Social Security Administration’s interpretation of the statutes in question within its lawful interpretative authority?
The Court held that the Agency's interpretations of the statute fell within its lawful interpretative authority. According to the Court, the Agency's construction was permissible, and made considerable sense in terms of the statute's basic objectives. The statute demanded some duration requirement, and the agency's interpretation consistently reconciled the statutory "impairment" and "inability" language. In addition, the agency's regulations reflected the Agency's own longstanding interpretation. Further, the court found that the language "can be expected to last" 12 months, at 42 U.S.C.S. § 423(d)(1)(A), did not say as of what time the law measured the "expectation." Read in context, the purpose of the phrase "can be expected to last" might have been of permitting the agency to award benefits before 12 months had expired, not one of denying the agency the benefit of hindsight. The agency's regulation seemed a reasonable, hence permissible, interpretation of the statute.
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