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Law School Case Brief

Heckler v. Campbell - 461 U.S. 458, 103 S. Ct. 1952 (1983)

Rule:

Certain impairments are so severe that they prevent a person from pursuing any gainful work. 20 C.F.R. § 404.1520(d). A claimant who establishes that he suffers from one of these impairments will be considered disabled without further inquiry. If a claimant suffers from a less severe impairment, the Secretary of Health and Human Services must determine whether the claimant retains the ability to perform either his former work or some less demanding employment. If a claimant can pursue his former occupation, he is not entitled to disability benefits. 20 C.F.R. § 404.1520(e). If he cannot, the Secretary must determine whether the claimant retains the capacity to pursue less demanding work. 20 C.F.R. § 404.1520(f)(1).

Facts:

A claimant applied for Social Security disability benefits because a back condition and hypertension prevented her from continuing her work as a hotel maid. After her application was denied, the claimant requested a hearing de novo before an administrative law judge. Relying on medical-vocational guidelines promulgated by the Secretary of Health and Human Services, the administrative law judge found that a significant number of jobs existed that a person of the claimant's qualifications could perform and therefore concluded that the claimant was not disabled. This determination was upheld by both the Social Security Appeals Council and the United States District Court for the Eastern District of New York. The United States Court of Appeals for the Second Circuit reversed, holding that the Secretary was required to introduce evidence that specific alternative jobs existed.

Issue:

Did the court of appeals' holding effectively prevent Heckler’s use of the medical-vocational guidelines by requiring her to identify specific alternative jobs in every disability hearing?

Answer:

Yes

Conclusion:

The Supreme Court of the United States held that the court of appeals erred in reversing the judgment because Heckler’s reliance on the medical-vocational guidelines was not inconsistent with the Social Security Act. 42 U.S.C.S. § 423(d)(2), which required that disability hearings be based on individualized determinations, did not bar Heckler from promulgating the medical-vocational guidelines, as the determination of whether jobs existed for a particular claimant was not unique to each claimant. Instead, the determination related to the types and numbers of jobs that existed in the national economy. Moreover, the medical-vocational guidelines had been promulgated in response to criticism that vocational experts at disability hearings inconsistently treated similarly situated claimants.

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