Heckler v. Campbell
461 U.S. 458 (1983)
Rule of Law:
The Secretary of Health and Human Services may rely on published medical-vocational guidelines to determine the existence of jobs in the national economy for a disability claimant, and is not required to introduce specific evidence of available jobs in each individual adjudication.
Facts:
- Carmen Campbell worked as a hotel maid until a back condition and hypertension prevented her from continuing her job.
- Campbell applied for Social Security disability benefits.
- An Administrative Law Judge (ALJ) found that while Campbell's condition prevented her from returning to her work as a maid, she retained the physical capacity to perform 'light work'.
- The ALJ determined Campbell's individual characteristics: she was 52 years old, had a limited education, and her previous employment consisted of unskilled jobs.
- The ALJ also noted that Campbell, originally from Panama, had some difficulty speaking and writing English, though she could understand and read it fairly well.
Procedural Posture:
- Carmen Campbell's application for disability benefits was denied by the Social Security Administration.
- Campbell received a de novo hearing before an Administrative Law Judge (ALJ), who found she was not disabled based on the medical-vocational guidelines.
- The Social Security Appeals Council upheld the ALJ's decision.
- Campbell sought judicial review in the U.S. District Court for the Eastern District of New York, which affirmed the Secretary's decision.
- Campbell, as appellant, appealed to the U.S. Court of Appeals for the Second Circuit, with the Secretary as appellee.
- The Court of Appeals for the Second Circuit reversed, holding the Secretary must introduce evidence of specific alternative jobs a claimant can perform.
- The Secretary of Health and Human Services petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does the Social Security Act permit the Secretary of Health and Human Services to rely on pre-published medical-vocational guidelines to determine a claimant's right to disability benefits, without introducing specific evidence of available jobs that the claimant could perform?
Opinions:
Majority - Justice Powell
Yes. The Social Security Act permits the Secretary to rely on the medical-vocational guidelines because the Act grants the Secretary broad authority to promulgate regulations for implementing the statute. The determination of disability involves two inquiries: an individualized assessment of the claimant's abilities and a general assessment of whether jobs exist in the national economy for a person with those abilities. While the first inquiry requires a case-by-case hearing, the second addresses a general factual issue that is not unique to each claimant and may be resolved fairly and efficiently through rulemaking. Relying on these guidelines promotes uniformity and relieves an overburdened agency from having to relitigate the existence of jobs in every single disability hearing. Claimants are still protected because they have the opportunity to present evidence showing that the guidelines do not accurately describe their particular limitations.
Concurring - Justice Brennan
Yes. While the medical-vocational guidelines are valid, the Administrative Law Judge in this case failed to adhere to the 'duty of inquiry.' An ALJ in a non-adversarial proceeding has a special duty to develop a full and fair record, especially when a claimant is unrepresented and has limited English fluency. The ALJ here failed to sufficiently question Campbell about her actual physical limitations or explore potential non-exertional impairments, which reflects poorly on the process even if the underlying regulations are permissible.
Concurring-in-part-and-dissenting-in-part - Justice Marshall
Yes, the guidelines are valid, but the Court of Appeals' decision to remand for a new hearing should have been affirmed. The central issue in Campbell's case was her ability to perform 'light work,' yet the ALJ never explained what that term meant or gave Campbell a meaningful opportunity to challenge that conclusion with respect to specific jobs. By failing to provide notice of the nature and demands of the jobs she was allegedly capable of performing, the ALJ deprived her of a real chance to present evidence in rebuttal. The lower court's requirement to list a few examples of jobs was a reasonable way to ensure the ALJ fulfilled the obligation to fully develop the facts.
Analysis:
This case is a foundational administrative law decision that validates the use of rulemaking to resolve recurring factual issues within adjudicatory proceedings. It affirms an agency's power to balance the need for individualized justice with administrative efficiency and uniformity. By approving the 'grid' regulations, the Court significantly shaped Social Security disability law, allowing the agency to handle a massive caseload without requiring vocational expert testimony in every case. The concurring opinions, however, underscore the ongoing tension, highlighting that while such efficient systems are permissible, they place a heightened 'duty of inquiry' on ALJs to ensure a claimant's individual circumstances are fully and fairly considered.
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