Heckler v. Edwards
Annotate this Case
465 U.S. 870 (1984)
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U.S. Supreme Court
Heckler v. Edwards, 465 U.S. 870 (1984)
Heckler v. Edwards
Argued November 30, 1983
Decided March 21, 1984
465 U.S. 870
Title 28 U.S.C. § 1291 grants federal courts of appeals jurisdiction over appeals from all final decisions of district courts, "except where a direct review may be had in the Supreme Court." Title 28 U.S.C. § 1252 provides in its first paragraph for such a direct appeal from a district court judgment holding an Act of Congress unconstitutional in any civil action to which the United States or any of its agencies, or an officer or employee thereof, is a party. Section 1252 further provides in its second paragraph that a party who has received notice of an appeal under the section shall take any subsequent appeal to the Supreme Court, and that all appeals taken to other courts prior to such notice shall be treated as taken directly to the Supreme Court. Respondent filed a class action in Federal District Court against petitioner Secretary of Health and Human Services, challenging the constitutionality of § 211(a)(5)(A) of the Social Security Act, which provides that all gross income and deductions derived from a family business in community property States shall be attributed to the husband unless the wife can establish that she exercised substantially all of the management and control of the business, in which case all income would be treated as the wife's. Although petitioner conceded the unconstitutionality of § 211(a)(5)(A)'s gender-based presumption, the District Court nevertheless rejected petitioner's claim of mootness, held the statute unconstitutional, and granted respondent's motion for summary judgment. The court then found the respondent class entitled retroactively to an allocation of co-proprietor income between the spouses' earnings accounts on the basis of labor contributed by each. Petitioner appealed to the Court of Appeals, challenging only the District Court's remedy. The Court of Appeals granted respondent's motion to dismiss the appeal for lack of jurisdiction under § 1291, because direct review could be had in this Court pursuant to § 1252.
Held: A party does not have a right to direct review in this Court under § 1252 unless the district court's holding of federal statutory unconstitutionality is in issue, and hence here the Court of Appeals improperly dismissed petitioner's appeal for lack of jurisdiction, since only the District Court's remedy was challenged. Pp. 465 U. S. 876-885.
(a) While a literal reading of § 1252 would seem to give a party a right to a direct appeal to this Court under the circumstances of this case, the
natural sense of § 1252 is that the holding of statutory unconstitutionality, not other issues such as attorney's fees, remedy, or related state law claims, is what Congress wished this Court to review in the first instance. Pp. 465 U. S. 877-879.
(b) Section 1252's structure supports this view. The conclusion inherent in that structure is that not all appeals in a case in which an Act of Congress has been held unconstitutional must be taken directly to this Court, the necessary corollary to the second paragraph of § 1252 being that, in the absence of a notice of appeal under § 1252, other appeals in the case will follow the normal route for appellate review. Because direct review is linked to a court's holding a federal statute unconstitutional, the logical test of which appeals from a judgment must be brought directly to this Court and which, standing alone, must follow the normal route of appellate review, is whether the issue on appeal is the holding of statutory unconstitutionality. Pp. 465 U. S. 879-880.
(c) The legislative history also supports the view that Congress considered the jurisdictional predicate for mandatory review by this Court to be appeal from the constitutional holding. Congress' concerns in enacting § 1252's predecessor about the separation of powers and the need for certainty and uniformity in the administration of federal law are not implicated in cases in which the Government concedes statutory unconstitutionality by its decision not to appeal that aspect of the district court's judgment. The only justification for exerting this Court's mandatory jurisdiction in a case such as this might be the considerable ramifications of district court orders, but serious consequences alone cannot support the exercise of such jurisdiction. Although remedial aspects of a case are important, the touchstone of direct appeal under § 1252 is not a party's or this Court's own judgment of the significance of a decision. In § 1252, Congress mandated direct review not simply for decisions with impact, but rather for decisions whose impact was predicated upon a potentially incorrect exercise of judicial review. A construction of § 1252 that would require this Court to review collateral issues as independent matters, rather than as pendent to the holding of statutory unconstitutionality, would undermine the effectiveness of the direct appeal provision. Pp. 465 U. S. 880-885.
Vacated and remanded.
MARSHALL, J., delivered the opinion for a unanimous Court.