Lawrence v. Chater

PETITIONER: Lawrence
RESPONDENT: Chater
LOCATION: Seminole Tribe

DOCKET NO.: 94-9323
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 516 US 163 (1996)
DECIDED: Jan 08, 1996

Facts of the case

Kemmerlyn Lawrence asserted entitlement to Social Security benefits as the dependant, unmarried minor child of a deceased insured individual. Under the Social Security Act, which requires paternity to be decided by state law, Lawrence acknowledged that her claim appeared defeated, but agued that the relevant North Carolina law's proof of paternity requirements are unconstitutional. After the Federal Government argued that a state paternity law's constitutionality need not be considered before applying it to determine entitlement to Social Security benefits, the Court of Appeals affirmed the denial of Lawrence's benefits. Subsequently, the Social Security Administration reexamined its position and concluded that the Act does require a determination whether a state intestacy statute is constitutional. The Solicitor General thus invited the Court to grant certiorari, vacate the judgment below, and remand the case (GVR) to the Court of Appeals to decide the case or remand it to the Social Security Commissioner for reconsideration.

Question

Does the U.S. Supreme Court have the authority to set aside a lower court's ruling and remand the case without finding that the lower court committed some error?