Heckler v. Campbell
Annotate this Case
461 U.S. 458 (1983)
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U.S. Supreme Court
Heckler v. Campbell, 461 U.S. 458 (1983)
Heckler v. Campbell
Argued February 28, 1983
Decided May 16, 1983
461 U.S. 458
To be entitled to disability benefits under the Social Security Act, a person must not only be unable to perform his former work but must also be unable, considering his age, education, and work experience, to perform any other kind of gainful work that exists in the national economy. Prior to 1978, in cases where a claimant was found unable to pursue his former occupation, but his disability was not so severe as to prevent his pursuing any gainful work, the Secretary of Health and Human Services (Secretary) relied on vocational experts to determine whether jobs existed in the national economy that the claimant could perform. In 1978, to improve the uniformity and efficiency of such determinations, the Secretary promulgated medical-vocational guidelines setting forth rules to establish whether such jobs exist. If a claimant's qualifications correspond to the job requirements identified by a rule, the guidelines direct a conclusion as to whether work exists that the claimant can perform. If such work exists, the claimant is not considered disabled. After respondent's application for disability benefits was denied, she requested a hearing before an Administrative Law Judge, who, relying on the guidelines, found that jobs existed that a person of respondent's qualifications could perform, and accordingly concluded that she was not disabled. Both the Social Security Appeals Council and the District Court upheld this determination. But the Court of Appeals reversed, holding that the guidelines did not provide adequate evidence of specific alternative jobs that respondent could perform, that, in the absence of such evidence, respondent was deprived of any chance to present evidence that she could not perform the types of jobs identified by the guidelines, and that therefore the determination that she was not disabled was not supported by substantial evidence.
Held: The Secretary's use of the medical-vocational guidelines to determine a claimant's right to disability benefits does not conflict with the Social Security Act, nor are the guidelines arbitrary or capricious. Pp. 461 U. S. 465-470.
(a) While the statutory scheme contemplates that disability hearings will be individualized determinations based on evidence, this does not bar the Secretary from relying on rulemaking to resolve certain classes of issues. The determination as to whether jobs exist that a person having
the claimant's qualifications could perform requires the Secretary to determine a factual issue that is not unique to each claimant, and may be resolved as fairly through rulemaking as by introducing testimony of vocational experts at each disability hearing. To require the Secretary to relitigate the existence of jobs in the national economy at each hearing would hinder an already overburdened agency. Pp. 461 U. S. 465-468.
(b) The principle of administrative law that, when an agency takes official or administrative notice of facts, a litigant must be given an adequate opportunity to respond is inapplicable where, as in this case, the agency has promulgated valid regulations. When the accuracy of such facts has been tested fairly during rulemaking, the rulemaking proceeding itself provides sufficient procedural protection. Pp. 461 U. S. 468-470.
665 F.2d 48, reversed.
POWELL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, BLACKMUN, REHNQUIST, STEVENS, and O'CONNOR, JJ., joined. BRENNAN, J., filed a concurring opinion, post, p. 461 U. S. 470. MARSHALL, J., filed an opinion concurring in part and dissenting in part, post, p. 461 U. S. 473