Schweiker v. Hansen
450 U.S. 785 (1981)
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Rule of Law:
The doctrine of equitable estoppel generally does not apply against the federal government based on the erroneous oral statements of its employees, especially when a claimant seeks public funds and has failed to comply with a valid regulation requiring a written application.
Facts:
- On June 12, 1974, respondent Hansen met with Don Connelly, a field representative of the Social Security Administration (SSA).
- Hansen orally inquired whether she was eligible for 'mother's insurance benefits.'
- Connelly erroneously informed Hansen that she was not eligible for the benefits.
- Contrary to the SSA's internal Claims Manual, Connelly did not advise Hansen of the advantages of filing a written application or recommend that she file one despite her potential ineligibility.
- Hansen did not file a written application at that time.
- In May 1975, Hansen learned from another source that she was, in fact, eligible for the benefits.
- Upon learning of her eligibility, Hansen filed a written application and began receiving benefits.
Procedural Posture:
- Hansen filed a written application and received benefits, including the maximum 12 months of retroactive benefits allowed by statute.
- Hansen initiated an administrative claim for an additional 12 months of retroactive benefits preceding her initial oral inquiry, which was denied by an Administrative Law Judge.
- The Social Security Appeals Council affirmed the denial of Hansen's claim.
- Hansen filed a lawsuit in the U.S. District Court for the District of Vermont, which ruled in her favor.
- The Secretary of Health and Human Services (petitioner) appealed to the U.S. Court of Appeals for the Second Circuit.
- A divided panel of the Second Circuit affirmed the district court's judgment in favor of Hansen.
- The Secretary petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the erroneous oral advice of a Social Security Administration employee, combined with his failure to follow an internal agency manual, estop the federal government from enforcing a valid regulation that requires a written application to receive benefits?
Opinions:
Majority - Per Curiam
No, the conduct of the Social Security Administration employee does not estop the government from enforcing its written application requirement. The Court has a duty to observe the conditions Congress defines for charging the public treasury, and a valid regulation requiring a written application cannot be overlooked based on an employee's oral error. The SSA's Claims Manual is an internal guide without the force of law, so an employee's failure to follow it does not create enforceable rights or justify estoppel. The employee's conduct, which did not rise to the level of 'affirmative misconduct,' falls far short of what would be required to estop the government from insisting on compliance with its valid regulations.
Dissenting - Justice Marshall
Yes, the government should be estopped from denying benefits in this case. This case presents an important and unsettled issue of when equitable estoppel applies to the government, making it inappropriate for a summary reversal. The majority's decision provides no clear guidance and simply adds confusion to the law. Connelly's misconduct directly caused Hansen's failure to comply with a purely procedural requirement, and it is unjust to penalize an individual who relies on the advice of a government agent. When governmental misconduct causes an individual to fail to comply with a procedural rule, the government should be estopped from denying benefits to which that person is substantively entitled.
Analysis:
This decision significantly reinforces the traditional rule of sovereign immunity that makes it very difficult to apply equitable estoppel against the federal government. By refusing to estop the government for an agent's negligent oral misstatement, the Court protects the public treasury from claims arising from the informal, and often erroneous, advice given by thousands of government employees. The ruling establishes that citizens rely on such oral advice at their peril and must adhere to formal statutory and regulatory requirements, like filing a written application. It also clarifies that internal agency manuals do not create legally enforceable rights for the public, thereby preserving agencies' discretion in managing their internal operations.
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