Barnhart v. Walton Case Brief

Facts of the Case

“The Social Security Act authorized payment of Title II disability insurance benefits and Title XVI Supplemental Security Income to individuals who have an “inability to engage in any substantial gainful activity by reason of any medically determinable . . . impairment . . . which has lasted or can be expected to last for a continuous period of not less than 12 months.” The Social Security Administration (Agency) denied benefits to respondent Walton, finding that his “inability” to engage in substantial gainful activity lasted only 11 months. The District Court affirmed, but the Fourth Circuit reversed, holding that the 12-month duration requirement modified “impairment” not “inability.” Moreover, the Fourth Circuit held that the statute left no doubt that no similar duration requirement relates to an “inability,” and that therefore Walton was entitled to benefits despite Agency regulations restricting them to those unable to work for 12 months. The court decided further that Walton qualified for benefits because, prior to his return to work, his “inability” would have been “expected” to last 12 months. The Court granted the government’s petition for certiorari.”


Did Louisville’s ordinance violate the Due Process Clause of the Fourteenth Amendment?


“Yes and yes. In a 9-0 opinion delivered by Justice Stephen G. Breyer, the Court held that the Social Security Administration’s interpretations of the statute fell within its lawful interpretative authority. Justice Breyer noted that the Administration has determined in both its formal regulations and its interpretation of those regulations that an “inability” must last the same amount of time as an “impairment,” or last or be expected to last not less than 12 months. “The statute’s complexity, the vast number of claims that it engenders, and the consequent need for agency expertise and administrative experience lead us to read the statute as delegating to the Agency considerable authority to fill in, through interpretation, matters of detail related to its administration,” concluded Justice Breyer.”

Case Information

Citation: 535 US 212 (2002)
Argued: Jan 16, 2002
Decided: Mar 27, 2002
Case Brief: 2002