Sullivan v. Zebley
493 U.S. 521 (1990)
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Rule of Law:
The Social Security Administration's regulation for determining child disability, which relies solely on whether a child's impairment meets or equals a listed impairment, is invalid because it is inconsistent with the Social Security Act's requirement that a child be considered disabled if their impairment is of "comparable severity" to one that would disable an adult. To comply with the statute, the agency must provide an individualized functional assessment for children whose impairments do not meet or equal a listing.
Facts:
- Congress enacted the Supplemental Security Income (SSI) program, which provides benefits to disabled individuals, including children.
- The Social Security Act defines a child as disabled if they suffer from a "medically determinable physical or mental impairment of comparable severity" to an impairment that would render an adult unable to engage in substantial gainful activity.
- The Secretary of Health and Human Services promulgated a five-step evaluation process for adult disability claims, which includes an individualized assessment of an adult's functional and vocational capacity if their impairment does not meet or equal a listed impairment.
- For child disability claims, the Secretary created an abbreviated process that ends the inquiry if the child's impairment does not meet or medically equal an impairment on a predetermined list.
- Unlike the process for adults, the child disability regulation does not include any individualized inquiry into how a child's impairment functionally affects their daily activities if their condition does not match a listing.
- Brian Zebley, a child with congenital brain damage, mental retardation, and other impairments, applied for SSI benefits.
- The Secretary denied Brian Zebley's application because his combination of impairments did not meet or medically equal any single listed impairment.
Procedural Posture:
- Brian Zebley, on behalf of himself and a class of similarly situated children, filed a class-action lawsuit against the Secretary of Health and Human Services in the U.S. District Court for the Eastern District of Pennsylvania.
- The District Court certified the class but later granted summary judgment in favor of the Secretary, upholding the validity of the regulations.
- The plaintiff class (appellants) appealed to the U.S. Court of Appeals for the Third Circuit, with the Secretary as appellee.
- The Court of Appeals vacated the District Court's judgment in part, holding that the regulations were inconsistent with the Social Security Act, and remanded with instructions to enter summary judgment for the plaintiff class.
- The Secretary of Health and Human Services successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Secretary of Health and Human Services' regulation, which determines a child's eligibility for Supplemental Security Income (SSI) benefits based solely on whether the child suffers from a listed impairment or its medical equivalent, violate the Social Security Act's requirement that a child be considered disabled if they suffer from an impairment of "comparable severity" to one that would prevent an adult from engaging in substantial gainful activity?
Opinions:
Majority - Justice Blackmun
Yes, the regulation violates the Social Security Act. The Secretary's listings-only approach for children is inconsistent with the statutory standard of "comparable severity" to an adult's disability. The statute requires an individualized, functional inquiry, which the Secretary provides for adults at steps four and five of the adult evaluation process but denies to children. The listings themselves are set at a higher standard of severity—precluding any gainful activity, not just substantial gainful activity—and are not exhaustive, meaning they exclude many children with impairments of comparable severity to those that would disable an adult. By failing to provide a final step for children that assesses the functional impact of their impairments on their daily lives, the regulation nullifies the congressional choice to link child disability to the more liberal, functional standard for adults and is therefore manifestly contrary to the statute.
Dissenting - Justice White
No, the regulation does not violate the Social Security Act. The statutory phrase "comparable severity" is ambiguous, as comparing a child's impairment to an adult's inability to work is like comparing apples and oranges. Given this ambiguity, the court should defer to the Secretary's reasonable interpretation of the statute. The listings-based approach is a permissible method for implementing the ambiguous congressional directive. The different purposes of the programs—income replacement for adults versus providing for a disabled child's special needs—justify the different evaluation methods. Any deficiencies in the regulations should be remedied through the appeal process in individual cases, not by a facial invalidation of the entire regulatory scheme.
Analysis:
This decision fundamentally changed the landscape of child disability law by invalidating the Social Security Administration's (SSA) long-standing "listings-only" approach. It forced the SSA to create and implement a new step in the child disability determination process: the individualized functional assessment (IFA). This ruling significantly broadened the path to eligibility, allowing benefits for children whose impairments, while severe, did not precisely match the rigid medical criteria of a listing but had a functional impact equivalent to a disabling adult impairment. The case established that functional equivalence, not just medical equivalence, is the standard, impacting hundreds of thousands of claims and leading to a more holistic and realistic evaluation of childhood disability.
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