Friday, November 1, 2013

Association of Administrative Law Judges v. Heckler case brief

Association of Administrative Law Judges v. Heckler case brief summary
594 F. Sup.. 1132 (D.D.C. 1984)

Plaintiff, a nonprofit corporation whose members were administrative law judges (ALJs), filed suit against defendants, the Department of Health and Human Services and the Office of Hearings and Appeals of the Social Security Administration (collectively federal agencies), alleging that the "Bellmon Review Program" violated the rights of its members to decisional independence under the Administrative Procedure Act (APA), 5 U.S.C.S. § 551 et seq.

The federal agencies instituted the "Bellmon Review Program" to implement § 304 of the Social Security Disability Amendments of 1980, Pub. L. No. 96-265. The nonprofit organization charged that the targeting of individual ALJs under Bellmon Review, based upon allowance rates and then own motion rates, was an attempt to influence ALJs to reduce their allowance rates and, thereby, compromised their decisional independence. The federal agencies' position was that there was no agency policy to reduce allowance rates. Rather, the policy was to reduce inconsistency in the application of law and regulations.

  • The court noted that the federal agencies' unremitting focus on allowance rates in the individual ALJ portion of the Bellmon Review Program created an untenable atmosphere of tension and unfairness which violated the spirit of the APA. 
  • The court ruled, however, that the need for injunctive relief or restructuring of the federal agencies was obviated by the fact that the federal agencies appeared to have shifted their focus by eliminating entirely the individual ALJ portion of Bellmon Review and increasing the number of cases reviewed under the national random sample.


The court entered judgment in favor of the federal agencies, and ordered the cause dismissed.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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