Heckler v. Campbell
Encyclopedia
Heckler v. Campbell, , 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.
. 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 his 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.
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 fairly well. 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 disabled was not supported by substantial evidence as required by the Social Security Act.
The court held that the Secretary’s reliance on the guidelines were not inconsistent with the Social Security Act, nor were they arbitrary and capricious.
Justice Brennan concurred but pointed out that the record contained very little evidence about Campbell's ability to do "light work."
Justice Marshall
dissented essentially on the same grounds.
United States Secretary of Health and Human Services
The United States Secretary of Health and Human Services is the head of the United States Department of Health and Human Services, concerned with health matters. The Secretary is a member of the President's Cabinet...
could rely on published medical-vocational guidelines to determine a claimant’s right to Social Security benefits.
Background
In 1978, the Secretary of Health and Human Services promulgated regulations in order to implement the statutory definition of disabilityDisability
A disability may be physical, cognitive, mental, sensory, emotional, developmental or some combination of these.Many people would rather be referred to as a person with a disability instead of handicapped...
. 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 his former work or some less demanding employment by creating a matrix that evaluated four factors that had been identified by Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
: physical ability, age, education, and work experience. Information was also compiled about what jobs were available.
Carmen Campbell claimed she had a back condition that kept her from working at her former job as a hotel maid
Maid
A maidservant or in current usage housemaid or maid is a female employed in domestic service.-Description:Once part of an elaborate hierarchy in great houses, today a single maid may be the only domestic worker that upper and even middle-income households can afford, as was historically the case...
. Ms. Campbell had been born in Panama
Panama
Panama , officially the Republic of Panama , is the southernmost country of Central America. Situated on the isthmus connecting North and South America, it is bordered by Costa Rica to the northwest, Colombia to the southeast, the Caribbean Sea to the north and the Pacific Ocean to the south. The...
, and though she had limited ability to speak and write English
English language
English is a West Germanic language that arose in the Anglo-Saxon kingdoms of England and spread into what was to become south-east Scotland under the influence of the Anglian medieval kingdom of Northumbria...
, she could read and understand English fairly well. 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
United States Court of Appeals for the Second Circuit
The United States Court of Appeals for the Second Circuit is one of the thirteen United States Courts of Appeals...
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 disabled was not supported by substantial evidence as required by the Social Security Act.
Opinion of the Court
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 were not inconsistent with the Social Security Act, nor were they arbitrary and capricious.
Justice Brennan concurred but pointed out that the record contained very little evidence about Campbell's ability to do "light work."
Justice Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
dissented essentially on the same grounds.