Jennings v. Illinois
342 U.S. 104 (1951)
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Rule of Law:
The Secretary of Health and Human Services may require a claimant for Social Security disability benefits to make a threshold showing that their impairment is medically severe enough to significantly limit their ability to perform basic work activities. A regulation allowing for the denial of benefits based on this medical determination alone, without considering the claimant's age, education, and work experience, is a facially valid exercise of the Secretary's statutory authority.
Facts:
- Janet Yuckert worked as a travel agent from 1963 to 1977 and later intermittently as a real estate salesperson.
- In October 1980, at the age of 45, Yuckert applied for Social Security disability benefits.
- She alleged disability based on an inner ear dysfunction, dizzy spells, headaches, an inability to focus her eyes, and flatfeet.
- During the time of her application, Yuckert was enrolled in a two-year computer programming course at a community college.
- Yuckert was also able to drive her car 80 to 90 miles each week.
Procedural Posture:
- Janet Yuckert's applications for disability insurance benefits and SSI were denied by the state agency acting for the Secretary.
- Upon reconsideration, the state agency again denied her claims.
- Yuckert then had a hearing before an Administrative Law Judge (ALJ), who found her impairments were not severe and denied the claim at step two of the sequential evaluation.
- The Social Security Appeals Council denied Yuckert's request for review, making the ALJ's decision the final decision of the Secretary.
- Yuckert filed a lawsuit in the United States District Court for the Western District of Washington, which affirmed the Secretary's denial of her claim.
- Yuckert, as appellant, appealed to the U.S. Court of Appeals for the Ninth Circuit, which reversed the District Court and held that the 'severity regulation' was facially invalid.
- The Secretary of Health and Human Services, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does a Social Security regulation that allows for the denial of disability benefits at a preliminary stage, based solely on a determination that the claimant's impairment is not 'medically severe' and without consideration of the claimant's age, education, and work experience, exceed the Secretary's authority under the Social Security Act?
Opinions:
Majority - Justice Powell
No, the regulation does not exceed the Secretary's authority. The Social Security Act grants the Secretary broad power to establish rules for determining disability, and the 'severity regulation' is consistent with the statute's language and legislative history. The Act defines disability in terms of an impairment's effect on one's ability to work, and if an impairment is not severe enough to significantly limit basic work activities, it cannot, by definition, prevent substantial gainful activity. The legislative history of amendments in 1967 and 1984 shows that Congress intended to emphasize medical factors and approved of the Secretary's sequential evaluation process, which includes this threshold severity screen for administrative efficiency.
Dissenting - Justice Blackmun
Yes, the regulation exceeds the Secretary's statutory authority. The regulation on its face directly contradicts the plain language of 42 U.S.C. § 423(d)(2)(A), which requires that a claimant's age, education, and work experience be considered if their impairment prevents them from performing their previous work. The majority errs by reading parts of the statute in isolation. The statutory structure makes clear that vocational factors are a mandatory component of the disability determination for those unable to perform past work, and the Secretary has no authority to create a regulation that bypasses this explicit congressional command.
Concurring - Justice O'Connor
No, the regulation is not facially invalid. A claimant who cannot demonstrate a significant limitation in basic work activities like walking, sitting, using judgment, or remembering instructions cannot possibly meet the statutory definition of disability. However, while facially valid, there is substantial evidence that the regulation has been systematically applied in a manner inconsistent with the statute to deny benefits to eligible claimants. The regulation is only permissible when used to screen out claimants with 'slight abnormalities' or de minimis impairments that could not be disabling under any vocational circumstances.
Analysis:
This decision solidifies the authority of the Social Security Administration to use its five-step sequential evaluation process, particularly the controversial 'step two' severity screen. By upholding the regulation's facial validity, the Court affirmed the agency's power to create efficient procedures to manage a vast number of claims by weeding out medically insignificant ones at an early stage. The case effectively shifted the legal battleground from challenging the regulation itself to challenging its application in specific cases, as emphasized by the concurrence, focusing on whether the severity standard is being set too high in practice.
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