Schweiker v. Hansen
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450 U.S. 785 (1981)
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U.S. Supreme Court
Schweiker v. Hansen, 450 U.S. 785 (1981)
Schweiker v. Hansen
Decided April 6, 1981
450 U.S. 785
Under § 6202(g)(1)(D) of the Social Security Act, "mother's insurance benefits" are available only to one who, among other qualifications, "has filed application." An implementing regulation provides that only written applications satisfy this requirement. A Social Security Administration (SSA) field representative erroneously told respondent that she was not entitled to such benefits. And contrary to instructions in SSA's Claims Manual, an internal handbook, he failed to recommend to respondent that she file a written application; nor did he advise her of the advantages of doing so. After subsequently learning that she was eligible for benefits, respondent filed a written application and sought retroactive benefits that she would have received if she had been properly advised by the field representative. Her claim for such retroactive benefits was denied in administrative proceedings, but the District Court found for her in her subsequent lawsuit. The Court of Appeals affirmed.
Held: The SSA field representative's erroneous statement and neglect of the Claims Manual did not estop the Secretary of Health and Human Services from denying retroactive benefits to respondent for the period in which she was eligible for benefits but had not filed a written application. The field representative's conduct was less than "affirmative misconduct," and does not justify abnegation of "the duty of all courts to observe the conditions defined by Congress for charging the public treasury." Federal Crop Insurance Corp. v. Merrill, 332 U. S. 380, 380 U. S. 385. Although the field representative failed to follow the Claims Manual, the Manual has no legal force, and does not bind the SSA. Nor is estoppel justified on the basis of any distinction between respondent's "substantive eligibility" and her failure to satisfy a "procedural requirement." A court is no more authorized to overlook the valid regulation requiring that applications be in writing than it is to overlook any other valid requirement for the receipt of benefits.
Certiorari granted; 619 F.2d 942, reversed.