Bowen v. Yuckert

482 U. S. 137

June 8, 1987

Janet Yuckert was trying to apply for some federal disability payment created by the Social Security Act. Regulations enacted to administer this disability benefit created a five step screening system to identify citizens who qualified. After being denied, Yuckert claimed that the second step in the regulatory system conflicted with the text of the law. The law said that disability benefits will be given in consideration of the claimant’s “age, educations, and work experience.” The second step in the regulatory process required that those factors be set aside for the moment, and the claimant would only move on to the next stage if they were severely disabled independent of those factors.

The Court ruled 6-3 that the regulatory system was Constitutional. Powell wrote for the majority, and said that no one was entitled to disability benefits without a severe disability. Thus, a step which focused merely on figuring out if such a disability existed was fine. That the vocational factors were not considered until a subsequent step was fine too, since disability itself was a crucial prerequisite. Powell further noted that Congress amended the Social Security Act in 1984, and seemed to express satisfaction at that time with the regulatory process, both in theory and in practice. Thus, the majority found no problem with the disability benefits system.

O’Connor concurred, and was joined by Stevens. She admitted that a great many potentially meritorious claims had been thrown out by step two in the regulatory process, but concluded that the system could be reformed from within, and that declaring the system in violation of the law was not necessary. Blackmun dissented, and was joined by Brennan and Marshall. He thought the law and the regulations were simply textually inconsistent, since the first said to consider vocational factors and the second said not to (at least at one stage). He provided some good inter-textual evidence to support his argument, and also tried to show that the legislative history supported his view as well. Blackmun dismissed the legislative history surrounding the 1984 amendments, calling it ambiguous.

As is often the case in statutory interpretation cases, I’m not quite sure who’s right. It’s possible that neither side is. It hardly takes a cynic to realize that sometimes Congress doesn’t know what the h*ll it’s passing. On occasion, a law simply will not be drafted thoughtfully enough to provide a decent answer to certain legal questions. The Supreme Court is stuck having to come up with an answer anyway – it’s no surprise then that the splits tend to be highly ideological. If the regulations enlarged the pool of disability beneficiaries rather than contracted it, I truly believe that the dissenters would be on the other side.


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