Note by Angela J. Paolini
The plaintiffs, representing a class of claimants seeking disability benefits under Title II of the Social Security Act, sought declaratory and injunctive relief from delays encountered in the hearing and appeals process established under Title II. The plaintiffs alleged that the delays suffered in obtaining a reconsideration determination and in securing a hearing before an administrative law judge (ALJ) constituted a violation of their rights to a hearing within a reasonable time under the Administrative Procedures Act (APA) and the Social Security Act (SSA) and of their rights under the due process clause of the fifth amendment to the United States Constitution.
The District Court for the District of Vermont granted a partial summary judgment to the plaintiff class, holding that delays of more than ninety days for either the processing of a reconsideration request or the holding of a hearing before an ALJ were unreasonable and violated the claimants' statutory rights. The court issued an injunction requiring the Secretary of Health and Human Services to issue reconsideration determinations and to conduct hearings within ninety days of receiving requests for such action. Moreover, any claimant who failed to obtain a reconsideration determination within 180 days of his request or a hearing within ninety days was entitled to receive interim benefits. The United States Court of Appeals for the Second Circuit, following its prior decisions in this area, affirmed the lower court's order.
The United States Supreme Court vacated the judgment and remanded the case, holding that the district court's injunction, in light of the manifested congressional intent to maintain the quality of disability determinations, constituted an unwarranted judicial intrusion into the heavily regulated province of the social security disability appeals process. Heckler v. Day, 104 S. Ct. 2249 (1984).
About the Author
Angela J. Paolini.
Citation
60 Tul. L. Rev. 205 (1985)