Friday, November 1, 2013

Heckler v. Campbell case brief

Heckler v. Campbell case brief summary
461 U.S. 458 (1983)

The district court affirmed the denial of benefits to respondent claimant. The United States Court of Appeals for the Second Circuit reversed the judgment, finding that the medical-vocational guidelines that had been promulgated by petitioner Secretary of Health and Human Services did not provide evidence of a specific job that was available for claimant. Secretary sought review.

Secretary argued that the court of appeals' holding effectively prevented her use of the medical-vocational guidelines by requiring her to identify specific alternative jobs in every disability hearing.

  • Upon review, the court held that the court of appeals erred in reversing the judgment because Secretary's reliance on the medical-vocational guidelines was not inconsistent with the Social Security Act, which required that disability hearings be based on individualized determinations, did not bar Secretary from promulgating the medical-vocational guidelines, as the determination of whether jobs existed for a particular claimant was not unique to each claimant; instead, the determination related to the types and numbers of jobs that existed in the national economy. 
  • Moreover, the medical-vocational guidelines had been promulgated in response to criticism that vocational experts at disability hearings inconsistently treated similarly situated claimants.


The court reversed the judgment.

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

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