Heckler v. Campbell Case Brief

Why is the case important?

The Respondent, Carmen Campbell (Respondent) applied for and was denied disability benefits. An administrative law judge agreed with the decision, concluding the Respondent was not disabled and the district court affirmed. The United States Court of Appeals for the Second Circuit reversed the judgment, finding that the medical-vocational guidelines that had been promulgated by the Petitioner, Heckler the Secretary of Health and Human Services (Petitioner) did not provide evidence of a specific job that was available for the Respondent. The Petitioner sought review.

Facts of the case

Question

May the Secretary of HHS rely on medical-vocational guidelines to determine a claimant’s right to Social Security disability benefits?

Answer

Yes. The Supreme Court held that the court of appeals erred in reversing the judgment because the Petitioner’s use of the medical-vocational guidelines to determine a claimant’s right to disability benefits did not conflict with the Social Security Act, nor were the guidelines arbitrary or capricious.

Conclusion

The Supreme Court of the United States held that the court of appeals erred in reversing the judgment because Heckler’s reliance on the medical-vocational guidelines was not inconsistent with the Social Security Act. 42 U.S.C.S. § 423(d)(2) , which required that disability hearings be based on individualized determinations, did not bar Heckler from promulgating the medical-vocational guidelines, as the determination of whether jobs existed for a particular claimant was not unique to each claimant. Instead, the determination related to the types and numbers of jobs that existed in the national economy. Moreover, the medical-vocational guidelines had been promulgated in response to criticism that vocational experts at disability hearings inconsistently treated similarly situated claimants.

  • Case Brief: 1983
  • Petitioner: Heckler
  • Respondent: Campbell
  • Decided by: Burger Court

Citation: 461 US 458 (1983)
Argued: Feb 28, 1983
Decided: May 16, 1983