Court Decisions

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Decisions issued by a court of judge.

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Crosby V. SSA

"It would be an unwarranted judicial intrusion into this pervasively regulated area for federal courts to issue injunctions imposing deadlines with respect to future disability claims." Suit for injunction requiring Social Security Administration to adjudicate claims for disability…

Munoz V. Sec'y HHS

McDonald V. Sec'y HHS

Step 2 (sequential evaluation) severity requirement is hereinafter to be a de minimus policy, designed to do no more than to screen out groundless claims. Various non-severe impairments viewed in combination may be disabling. SSR 85-28. See "severity" for discussion. Various non-severe…

Dvareckas V. Sec'y HHS

Absent a colorable constitutional claim not present here, a district court does not have jurisdiction to review the Secretary's discretionary decision not to reopen an earlier adjudication. Appeal barred by res judicata where, even though claimant's second application was not identical to…

Irving Independent School District v. Tatro. 468 US 883 (1984)

US Supreme Court, Justice Rehnquist
Eight year old student with spina bifida required CIC (clean intermittent catherization) every three - four hours to prevent kidney damage.  The court determined that CIC was a related service under IDEA and not a medical service.  The court also determined that 504 was inapplicable…

Hendrick Hudson Board of Education v. Rowley.

US Supreme Court, Justice Rehnquist
Supreme Court case that interprets and defines the statutory term, Free and Appropriate Public EducationParents requested a sign language interpreter which was denied by the school district.  The District Court found for the parents. Although the child performed better than the average child in her…

Suarez V. Sec'y HHS

Inadequacy of representation, noted by court, doesn't warrant reversal of non-disability decision, but court suggests claimant get a new lawyer and attempt reopening. cert. denied 474 U.S. 844 88 L.Ed.2d 109, 106 S.Ct. 133 (1985); rehearing denied 474 U.S. 1097, 88 L.Ed.2d 911, 106 S.Ct. 872 (1986).

Hebert V. Sec'y HHS

Making an error of law does not constitute bias. The fact that the claimant was committed as a "sexually dangerous person" does not mean that he is disabled under the Social Security Act.

Garcia V. Sec'y HHS

Unmarried 2nd wife is not entitled to benefits as a "deemed" widow where wage earner did not divorce his first wife.

Crooker V. EPA

EAJA does not authorize award of attorney's fees to pro se litigants.

Sierra Club V. Marsh

Basic requirements of EAJA

Krafsur V. Sec'y HHS

Since plaintiff failed to raise sequential evaluation issue, the court does not have to consider the overall validity of the process. Claimant's work difficulties "stemmed from personality problems that were not such as to constitute mental disability."

Avery V. Sec'y HHS

Generally, a remand order is an interlocutory order that does not divest a court of jurisdiction over a case. Absent a clear statement to the contrary, legislation should not ordinarily be interpreted to oust a federal court's equitable power, or its jurisdiction over a pending case. Social…

Nieves V. Sec'y HHS

ALJ is not at liberty to substitute her own opinions of an individual's health for uncontroverted medical evidence. ALJ erred in discrediting IQ scores where such test results are the only evidence on the point before the ALJ. It was error for ALJ to conclude that IQ score of 63 must be invalid…

MA Association of Older Americans V. Comm'r of Public Welfare

Contemp action. Mass. Department of Public Welfare's (now called Department of Transitional Assistance) policy of automatic termination of Medicaid when AFDC or SSI benefits declared invalid. DPW may not terminate the Medicaid benefits of any recipient whose AFDC or SSI benefits have been or are…

Cruz v Commissioner

SJC
This is a 1985 decision of the SJC analyzing the meaning of the phrase "permanently residing under color of law" (PRUCOL) as it was then used in federal Medicaid regulations. Federal Medicaid has not used the phrase PRUCOL since Congress enacted  PRWORA in 1996, but PRUCOLis still used in state…

Com. of Mass. V. Sec'y HHS

Aff'd in part, vacated in part, 816 F.2d 796 (1st Cir.1987), cert. granted, Bowen v. Massachusetts, 484 U.S. 1003, 108 S.Ct. 693, 98 L.Ed.2d 645 (1988), aff'd in part, rev'd in part, Bowen v. Massachusetts, 487 U.S. 879, 108 S.Ct. 2722, 101 L.Ed.2d 749 (1988). State entitled to reimbursement from…

Carillon Marin V. Sec'y HHS

"Good cause" for remand due to Secretary's failure to develop record. ALJ is not at liberty to substitute his own impression of an individual's health for uncontroverted medical opinion. Given unchallenged diagnosis of chronic schizophrenia, coupled with uncontradicted testimony…

Gray V. Heckler

Approves administrative notice of occupational reference materials for information regarding various types of work. Court notes that the 4th circuit has held that the Secretary may rely on general categories in the Supplement to the DOT as presumptively applicable to the claimant's past work.…

Winn V. Heckler

Claimant's fully healed right knee fusion does not constitute a medically determinable cause of claimant's subjective complaints of disabling pain. Subjective complaints of pain must be considered and evaluated, but only if there is a medically determinable impairment that could cause the pain.…

Sierra Club V. Sec'y of Transportation

Manfredonia v. Heckler, No. 83-1776, 740 F.2d 952

Campbell, C.J.
Possibility of mental impairment causing failure to take medication where medical report states that non-compliance "may be inherent to suspicious paranoia." "It could be unfair for the Secretary to refuse to give disability benefits under § 404.1530 if the claimant's mental…

Gagen v. Schweiker, No. 83-1780, 740 F.2d 952

per curiam -- Campbell, CJ; Coffin, Breyer, JJ
Case remanded to resolve discrepancy between DDS examiner, who concluded claimant had a severe impairment and could not return to former heavy work, and ALJ who found claimant could return to former work and gave no explanation for rejecting the examiner's opinion.

Chevron U.S.A. V. Natural Resources Defense Council

When a court reviews an agency's construction of a statute which it administers, there are 2 issues: (1) if Congress spoken to the issue, the court must give effect to the unambiguously expressed intent of Congress; (2) if the statute is silent or ambiguous on an issue, the court must determine…

Diaz V. Sec'y HHS

Mental retardation listing for children does not require use of the lowest I.Q score in determining whether impairment meets the listing.

Borrero Lebron V. Sec'y HHS

Secretary was entitled to apply Grid despite claimant's moderate anxiety neurosis, because the court finds substantial support for Appeals Council finding that the level of work the claimant can do is not affected by the nonexertional limitations.

Zayas v. Sec

per curiam -- Campbell, CJ; Coffin, Breyer, JJ
No substantial evidence that hypertension not controlled because of claimant's failure to follow prescribed treatment. Any departure from a grid rule must, at a minimun, be explained. ALJ made factual errors in application of grid. Remanded.

Doe V. Sec'y HHS

Federal courts may not review some types of "final" SSI decisions of ALJs.

Lopez-Cardona V. Sec'y HHS

20 CFR

Heckler V. Day

Court abolished judicially imposed mandatory time limits for ALJ hearings and decisions because they fail to take into account the differences in the facts and circumstances of each individual case. Delays may be analyzed for reasonableness only in the context of individual cases, and so any…

St. Elizabeth's Hosp. of Boston V. Sec'y HHS

Affirms Secretary's decision that hospital's neurology/neurosurgery unit and its interim coronary care unit were not special care units for purposes of Medicare reimbursement.

Burgos Lopez V. Heckler

Pain can constitute a significant nonexertional impairment which precludes naked application of the Grid and requires use of a vocational expert. The medical-vocational guidelines are not dispositive of the status of persons whose exertional limitations are further complicated by other…

Carrasquillo v. Sec

per curiam -- Campbell, CJ; Coffin, Breyer, JJ
Reopening for revision of earnings record (20 CFR §404.990) supplants reopening for good cause (20 CFR §404.989).

Rowan v. Sec

per curiam -- Campbell, CJ; Coffin, Breyer, JJ
Remand for taking of further VE testimony in regard to perceptual dysfunction (person with one eye).

Oldham V. Sec'y HHS

Court affirms Appeals Council's finding that plaintiff's informal work relationship with his wife and mother-in-law did not constitute employment for purpose of old-age insurance coverage. In a case involving closely related and closely living individuals claiming an employer-employee…

Scott V. Schweiker

Usher V. Sec'y HHS

The purpose of the Privacy Act, 5 U.S.C.

Kozera V. Spirito

Step-parent to child deeming and federal financial participation in states' welfare programs.

Sitar V. Schweiker

A treating physician's opinion may be rejected by the Secretary, who may accord greater weight to his own experts. Treating physician's diagnosis is not necessarily entitled to more weight than CEs.

Ayuso-Morales V. Sec'y HHS

Widow did not qualify for widow's Social Security benefits where she cohabitated for 20-years with her future husband in jurisdiction not recognizing "common law marriages" and married husband less than nine months before his death. Widow's status, under Puerto Rican law, as "concubine" for purpose…

Vasquez V. Sec'y HHS

Transferable Skills. Grids. Court remanded where ALJ relied on Grid rule requiring transferrable skills but failed to find explicitly (or to indicate the basis for his implicit finding) that 55-year old claimant's skills were transferable. The claimant has the burden of showing disability…

Dolbashian V. Sec'y HHS

Although claimant's profit was not significant and may be attributable in part to the gratuitous assistance he received from others, this does not prevent a finding that the activity was gainful and that profit resulted in part from his efforts. Supervisory, managerial, advisory or other…

Pitchard V. Schweiker

Lopez-Diaz V. Sec'y

ALJ can base adverse decision on claimant's ability to do past work which claimant did more than 15 years ago, the 15 year limit applies only to transferability under a grid analysis, and the grid comes into play only after a finding that the claimant cannot perform past work.

Sherwin V. Sec'y

The burden of showing the existence of other jobs in the national economy that the claimant can perform (Step 5) rests on the Secretary. Cert. denied, 461 U.S. 958, 103 S.Ct. 2432, 77 L.Ed.2d 1318 (1983). Good explanation of purpose and use of the Grids. The Grids are based on a claimant's…

Arocho V. Sec'y HHS

Sit-Stand Option. Remand where hypothetical to vocational expert asked about jobs in which the claimant could "alternate position, sit or stand," and VE's did not state whether jobs listed were available on a part-time basis or could be performed while walking. The ALJ's report…

Tremblay V. Sec'y HHS

Although views of medical advisor are not always by themselves substantial evidence when medical advisor does not examine claimant, this rule is of limited value in a case involving a condition alleged to have existed many years before, and where claimant's proof of disability is slight.…

Torres V. Sec'y HHS

Where the Medical-Vocational Guidelines require a finding of "not disabled," the ALJ need not name specific jobs that the claimant could perform.

Deblois V. Sec'y HHS

Neither absence of treatment records from relevant time period and retrospective nature of treating doctor's opinion justify ALJ's finding that treating source's report was too speculative a basis for establishing a severe impairment. (remanding for ALJ to obtain retrospective opinions…

Goodermote V. Sec'y HHS

Although plaintiff has several impairments, court holds that there was considerable evidence in the record that he was able to work with these problems for many years. Further, plaintiff's mental impairment is found to be non-severe, although it moderately restricts five out of ten basic…