Barnhart v. Walton
535 U.S. 212 (2002)
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Rule of Law:
Under the Social Security Act, an administrative agency's interpretation of a statutory provision is permissible if the statute is ambiguous and the interpretation is reasonable. This deference extends to regulations requiring a claimant's inability to work to last 12 months and using a claimant's actual return to work to determine if that inability was 'expected to last' for the required duration.
Facts:
- Cleveland Walton developed a serious mental illness, including schizophrenia and depression.
- On October 31, 1994, this illness caused Walton to lose his full-time job as a teacher.
- For the next eleven months, Walton's illness prevented him from engaging in any substantial gainful activity.
- By mid-1995, Walton began working part-time as a cashier.
- By December 1995, approximately 11 months after the onset of his inability to work, Walton was working as a cashier full-time, which constituted substantial gainful activity.
Procedural Posture:
- Cleveland Walton applied to the Social Security Administration (Agency) for disability benefits.
- The Agency denied his application, finding his inability to engage in substantial gainful activity did not last for the required 12 months.
- Walton sought judicial review in the U.S. District Court, which affirmed the Agency's decision.
- Walton, as appellant, appealed to the U.S. Court of Appeals for the Fourth Circuit, with the head of the Agency as appellee.
- The Court of Appeals for the Fourth Circuit reversed the district court's judgment, holding the Agency's interpretations of the statute were unlawful.
- The U.S. government, on behalf of the Agency, petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Is the Social Security Administration’s regulation, which requires a claimant's 'inability to engage in any substantial gainful activity' to last for 12 months and uses hindsight to determine if that inability was 'expected' to last that long, a permissible construction of the Social Security Act?
Opinions:
Majority - Justice Breyer
Yes, the Social Security Administration's regulation is a permissible construction of the Social Security Act. Under the Chevron framework, the statute is ambiguous regarding the duration requirement for the 'inability' to work. While the 12-month clause linguistically modifies 'impairment,' the statutory silence creates ambiguity. A fair inference from the statute's structure is that the impairment must be severe enough to prevent substantial gainful work for 12 months, which is the virtual equivalent of the 'inability' lasting 12 months. The Agency's interpretation is a permissible and reasonable way to resolve this ambiguity, as it serves the statute's purpose of filtering out short-term disabilities and reflects a longstanding agency position that Congress has not disturbed. Similarly, the statute is ambiguous as to the point in time from which to assess whether an inability 'can be expected to last' 12 months. The Agency's use of hindsight is a reasonable method to avoid unwieldy, contrary-to-fact speculation and is entitled to deference given the complexity of the benefits program.
Concurring - Justice Scalia
Yes. Deference is owed to the Social Security Administration's regulations because they were promulgated through formal notice-and-comment rulemaking and represent a permissible construction of the statute. However, the majority's reliance on the 'longstanding' nature of the agency's prior, less formal interpretations is an anachronistic relic of pre-Chevron jurisprudence. Under Chevron, the reasonableness of the current interpretation is what matters, not its antiquity or the agency's historical consistency. The Court should not have delved into old agency manuals and rulings, as the validity of the current, formally adopted regulations is sufficient to decide the case.
Analysis:
This decision significantly reinforces the doctrine of Chevron deference, affirming the power of administrative agencies to interpret ambiguous statutes, especially within complex regulatory schemes like Social Security. By upholding the agency's use of hindsight and its strict application of the 12-month duration requirement to the actual 'inability' to work, the Court grants the agency substantial leeway in formulating administrable rules. This ruling makes it more difficult for claimants to challenge agency regulations that fill statutory gaps, solidifying the agency's role as the primary interpreter of its governing statutes and potentially narrowing the path to eligibility for some applicants.
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