LOCATION: United States District Court Eastern District of Michigan
DOCKET NO.: 00-1937
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fourth Circuit
CITATION: 535 US 212 (2002)
ARGUED: Jan 16, 2002
DECIDED: Mar 27, 2002
Jeffrey A. Lamken - Argued the cause for the petitioner
Kathryn L. Pryor - Argued the cause for the respondent
Facts of the case
The Social Security Act authorizes 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." After developing a serious mental illness, Cleveland Walton lost his job as a teacher in October 1994. Eleven moths later, Walton was working as a cashier. When Walton applied for Title II disability insurance benefits and Title XVI Supplemental Security Income, the Social Security Administration denied him benefits, reasoning that his "inability" to engage in substantial gainful activity lasted only 11 months. The District Court affirmed. In reversing, the Court of Appeals held that the 12-month duration requirement modifies "impairment" not "inability," that no similar duration requirement relates to an "inability," and that, therefore, Walton was entitled to benefits despite regulations restricting them to those unable to work for 12 months. Further, the appellate court concluded that Walton qualified for benefits since, prior to his return to work, his "inability" would have been "expected" to last 12 months.
Does the term "inability," in the Social Security Act, include a 12 month requirement, such that the inability must last, or must be expected to last, for at least 12 months? Is the term "expected to last" applicable only when the "inability" has not yet lasted 12 months?
Media for Barnhart v. WaltonAudio Transcription for Oral Argument - January 16, 2002 in Barnhart v. Walton
Audio Transcription for Opinion Announcement - March 27, 2002 in Barnhart v. Walton
William H. Rehnquist:
The opinion on the court number 00-1937 Barnhart against Walton will be announced by Justice Breyer.
Stephen G. Breyer:
This is a Social Security Act case that deals with a provision that defines benefits for disabled people and it defines disability as "an inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months."
Now, the case raises two questions about that definition: first, consider a person say has serious high blood pressure and that high blood pressure which is his physical impairment lasts for more than 12 months, so that fit within the definition, but his inability to engage in substantial gainful employment i.e. his inability to work lasts for only 5 or 6 months and as he returns to work early but he still has the disease.
Well does he qualify?
Does most of the disability and the inability to work have to last for the 12 months or is it good enough to just the impairment last for 12 months?
Well for the last 40 years the Social Security agencies said both.
You have to both have the impairment and you cannot work for the 12 months, but the Fourth Circuit decided that that was unlawful so we reviewed that, and in our opinion the Social Security agency's determination is lawful.
It has been the statute at least ambiguous on the point and their decision that how to interpret that statute is a reasonable one, so we uphold their decision.
Now, the second question was what about a person, the same person, he comes back to work after 5 months, and his argument is well I maybe I did come back after 5 months instead of 12, but the statute uses the word expected to last more than 12 months and it was a surprise that I came back; I could have been expected to stay out for more than 12 months.
Now, can he make that argument?
Well, again the Social Security agency said, no, you did return after 5 months and that is the end of it, you got back before the 12 month period that is the end of it.
The Fourth Circuit thought the agency was wrong but we again say that the statute is ambiguous on the point and their determination is reasonable so we uphold the agency.
If you would like to read more about it, it is all set out in our opinion.
Our decision is unanimous, except to its part two in respect to which Justice Scalia has filed a concurring opinion.