Barnhart v. Walton

Supreme Court of the United States · 2002 · Administrative Law

Administrative LawSocial SecurityAgency DeferenceStatutory InterpretationChevronSocial Security Actdisabilitysubstantial gainful activity

Facts

The Agency found that by October 31, 1994, Walton had developed a serious mental illness involving schizophrenia and associated depression, which caused him to lose his full-time teaching job. By mid-1995 he returned to part-time work as a cashier, and by December 1995 he was working full time. The Agency concluded that his illness prevented him from engaging in substantial gainful activity for 11 months, from October 31, 1994 through the end of September 1995, and denied benefits because the statute required 12 months. Walton argued that the 12-month requirement did not apply to inability to work and, alternatively, that before he returned to work his condition could have been expected to last 12 months, making his later work part of a trial work period.

Issue

Whether the Social Security Administration lawfully interpreted the statutory definition of disability to require that the claimant's inability to engage in substantial gainful activity last, or be expected to last, at least 12 months. Also, whether the Agency lawfully interpreted the statute to treat an actual return to work before 12 months and before any disability determination as defeating the duration requirement rather than asking retrospectively whether the inability could have been expected to last 12 months.

Rule

Under Chevron, when the Social Security Act's definition of disability is ambiguous, the SSA may adopt a permissible interpretation through regulation. It is lawful for the SSA to interpret the Act to require that both the impairment and the resulting inability to engage in substantial gainful activity last, or be expected to last, for a continuous period of not less than 12 months, and to treat an actual pre-decision return to substantial gainful activity within 12 months as determinative against eligibility rather than engaging in retrospective speculation about what earlier might have been expected.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Elena Cruz applies for federal disability benefits after a spinal condition keeps her from working as a warehouse supervisor for 9 months, though the condition itself continues for more than 2 years. The administering agency has a regulation requiring both the medical impairment and the resulting inability to engage in substantial gainful activity to last, or be expected to last, at least 12 months.

If Elena argues that the statute's 12-month language grammatically modifies only "impairment," what is the strongest response under the governing doctrine?

Explanation. The majority held that although the 12-month phrase linguistically modifies "impairment," that silence does not resolve the duration of the inability to engage in substantial gainful activity; it creates ambiguity. Because requiring an impairment to remain severe enough to prevent substantial gainful activity for 12 months is virtually equivalent to requiring the inability itself to last 12 months, the agency's interpretation is a permissible construction under Chevron.