Heckler v. Day

LOCATION: Men’s Central Jail

DOCKET NO.: 82-1371
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the Second Circuit

CITATION: 467 US 104 (1984)
ARGUED: Dec 05, 1983
DECIDED: May 22, 1984

J. Paul Mc Grath - on behalf of the Petitioner
J. Paul McGrath - for petitioner
Paul McGrath - Argued the cause for the petitioner
Richard H. Munzing - Argued the cause for the respondent

Facts of the case

Title II of the Social Security Act (Act) establishes a four-step review process of disputed disability benefit claims. First, a state agency determines if a claimant has a disability and when the condition began or ended. Second, state agencies' disability determinations can be reviewed upon the claimant's request. Third, if upon review the claimant suffers an adverse finding he or she may demand an evidentiary hearing by an administrative law judge. Fourth, if a claimant is dissatisfied with the administrative law judge's decision, they may appeal to the Appeals Council of the Department of Health and Human Services (HHS). Claiming delays in excess of 90 days, during steps two and three, Leon Day sued on behalf of several similarly aggrieved Vermont claimants alleging a violation of the "reasonable time" hearing limitation. On appeal from the Second Circuit Court of Appeal's ruling upholding a district court's imposition of disability hearing deadlines, the Supreme Court granted HHS Secretary Margaret Heckler certiorari.


Does the judiciary's imposition of deadlines by which disability claims must be processed constitute an unconstitutional interference with a legislatively mandated statute?

Media for Heckler v. Day

Audio Transcription for Oral Argument - December 05, 1983 in Heckler v. Day

Warren E. Burger:

We will hear arguments next in Heckler against Mathews.

We will hear arguments first this morning in Heckler against Day.

Mr. McGrath, you may proceed whenever you are ready.

J. Paul Mc Grath:

Mr. Chief Justice and, may it please the Court:

The District Court here imposed mandatory time limits on the processing of Social Security disability claims, Title II claims, in the State of Vermont.

That order was based on a finding that the Secretary had violated the Social Security Act because, in the District Court's view, disability claims were not being decided quickly enough.

The statute in question, which is Section 205(b) of the Social Security Act, requires that claimants be given, and I quote,

"reasonable notice and opportunity for a hearing. "

The statute does not contain any mandation of time limits nor does it refer to timeliness as a requirement.

The issue here then is what did Congress require by this broad statutory mandate?

And, in turn, since the Secretary, under Section 205(a), has full power to issue rules, regulations, and procedures to carry out the Social Security Act.

The further issue is whether the Secretary acted arbitrarily and capriciously in not promulgating mandatory time limits.

We urge that the critical point here is this: Both congress and the Secretary looked long and hard at whether mandatory time limits should be imposed.

Both concluded that mandatory time limits would tend to undermine the effective operation of the Social Security disability system.

I take it, Mr. McGrath, you acknowledge that the Secretary has the power to issues regulations imposing such effort.

J. Paul Mc Grath:

Yes, we do, Justice Blackmun.

In that context, we urge that it was totally inappropriate for the District Court to overrule the policy choice made by Congress and the Secretary.

The Social Security disability system is a very complex management problem and there are three reasons for this.

One is that the number of claims has been rapidly expanding.

There were more than two million disability claims last year.

The second thing is that many of these claims present very difficult physical and mental and economic issues, especially since many of the claimants themselves are unable to present their claims effectively because of their very situation.

And, third, and perhaps most troublesome as a management matter, the statute gives the Secretary three quite conflicting mandates.

One is to pay claimants who are eligible as quickly as possible.

But, secondly, given the dollars involved in the program, it is equally important that claimants not entitled to benefits not be paid.

And, finally, the Secretary is under an obligation to conduct the program as fairly and accurately and uniformly as possible.

Over the last ten years, Congress and the Secretary have wrestled with how best to manage the program given these conflicting concerns.

Each of them has considered on a number of occasions the imposition of mandatory time limits and each has decided against such imposition, even though they recognized that that would undoubtedly result in faster decisions in many cases, they also recognized that it almost certainly would result in many more wrong ones.

First, I would like to focus on what Congress did.

For one thing, Congress, on a number of occasions, has amended the Social Security Act in a manner that is inconsistent with any intent to impose mandatory time limits, and I want to mention just two instances.

One is that when it established the Supplemental Security Income program, the SSI program, which is part of the Social Security system, it had put into the statute the same reasonable notice and opportunity for a hearing requirement.