Heckler v. Day

• Decision Date: 22 May 1984
• Docket Number: 82-1371
• Citation: 467 U.S. 104
• Parties: HECKLER, SECRETARY OF HEALTH AND HUMAN SERVICES v. DAY ET AL.
• Court: U.S. Supreme Court

467 U.S. 104

HECKLER, SECRETARY OF HEALTH AND HUMAN SERVICES v DAY ET AL.

No. 82-1371

Supreme Court of United States

Argued December 5, 1983

Decided May 22, 1984

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

Assistant Attorney General McGrath argued the cause for petitioner. With him on the briefs were Solicitor General Lee, Deputy Solicitor General Geller, Edwin S. Kneedler, and John F. Cordes.

Richard H. Munzing argued the cause for respondents. With him on the brief was Henry A. Freedman.^*

JUSTICE POWELL delivered the opinion of the Court.

The question presented is the validity of an injunction issued on behalf of a statewide class that requires the Secretary of Health and Human Services to adjudicate all future disputed disability claims under Title II of the Social Security Act, 42 U. S. C. § 401 et seq., according to judicially established deadlines and to pay interim benefits in all cases of noncompliance with those deadlines.

I.

Title II of the Social Security Act (Act) was passed in 1935. 49 Stat. 622, as amended, 42 U. S. C. § 401 et seq. Among other things, it provides for the payment of disability insurance benefits to those whose disability prevents them from pursuing gainful employment. 42 U. S. C. § 423.¹ Disability benefits also are payable under the Supplemental Security Income (SSI) program established by Title XVI of the Act, 76 Stat. 197, as amended, 42 U. S. C. § 1381. The disability programs administered under Titles II and XVI "are of a size and extent difficult to comprehend." Richardson v. Perales, 402 U. S. 389, 399 (1971). Approximately two million disability claims were filed under these two Titles in fiscal year 1983.² Over 320,000 of these claims must be heard by some 800 administrative law judges each year.³ To facilitate the orderly and sympathetic administration of the disability program of Title II, the Secretary and Congress have established an unusually protective four-step process for the review and adjudication of disputed claims. First, a state agency determines whether the claimant has a disability and the date the disability began or ceased.⁴ 42 U. S. C. § 421(a); 20 CFR § 404.1503 (1983). Second, if the claimant is dissatisfied with that determination, he may request reconsideration of the determination. This involves a de novo reconsideration of the disability claim by the state agency and in some cases a full evidentiary hearing. §§ 404.907-404.921. Additional evidence may be submitted at this stage, either on the request of the claimant or by order of the agency. Third, if the claimant receives an adverse reconsideration determination, he is entitled by statute to an evidentiary hearing and to a de novo review by an Administrative Law Judge (ALJ). 42 U. S. C. § 405(b); 20 CFR §§ 404.929-404.961 (1983). Finally, if the claimant is dissatisfied with the decision of the ALJ, he may take an appeal to the Appeals Council of the Department of Health and Human Services (HHS).⁵ §§ 404.967-404.983. These four steps exhaust the claimant's administrative remedies. Thereafter, he may seek judicial review in federal district court. 42 U. S. C. § 405(g).

In this class action, the named plaintiffs sought declaratory and injunctive relief from delays encountered in steps two and three above. The action was initiated by Leon Day in November 1978 after his disability benefits were terminated and he suffered substantial delays in obtaining a reconsideration determination and in securing a hearing before an ALJ.⁶ After suffering similar delays, Amedie Maurais intervened in the action.⁷ On June 14, 1979, the District Court certified a statewide class consisting of:

"All present and future Vermont residents seeking to secure Social Security disability benefits who, following an initial determination by the defendant that no disability exists, experience an unreasonable delay in the scheduling of and/or issuance of decisions in reconsiderations and fair hearings." App. to Pet. for Cert. 12a, n. 1.

Plaintiffs argued before the District Court that the delays they had experienced violated their statutory right under 42 U. S. C. § 405(b) (1976 ed., Supp. V) to a hearing within a reasonable time.⁸ Both parties submitted the case to the District Court on motions for summary judgment. On the basis of the undisputed evidence, the District Court held that, as to all claimants for Title II disability benefits in Vermont, delays of more than 90 days from a request for hearing before an ALJ to the hearing itself were unreasonable.⁹ It granted partial summary judgment to the plaintiff class on that issue in December 1979.

After the submission of additional evidence, the District Court considered motions for summary judgment concerning the reasonableness of delays in the reconsideration process. The additional evidence also was undisputed. It consisted of factual summaries of 77 randomly selected disability cases submitted by the Secretary. The District Court noted that the "summaries support the positions of both parties. They show the reconsideration process is often time consuming and complex. They also show that the process is replete with unexplained delay; other requests are processed with commendable dispatch." App. to Pet. for Cert. 25a. In 27 of the 77 cases, reconsideration determinations took longer than 90 days. In each of these 27, the District Court concluded that the delays were caused by agency inefficiencies and were not justified by the "necessary steps in the reconsideration process." Id. , at 28a. On the basis of this survey, the District Court concluded that, as a rule, delays of more than 90 days in making reconsideration determinations were unreasonable and violated the claimant's statutory rights.¹⁰ In August 1981, the District Court granted summary judgment for respondents on the reconsideration aspect of the case.

In November 1981, the District Court issued an injunction in favor of the statewide class that "ordered and directed [the Secretary] to conclude reconsideration processing and issue reconsideration determinations within 90 days of requests for reconsideration made by claimants."¹¹ The injunction also required ALJs to provide hearings within 90 days after the request is made by claimants.¹² Finally, it ordered payment of interim benefits to any claimant who did not receive a reconsideration determination or hearing within 180 days of the request for reconsideration or who did not receive a hearing within 90 days of the hearing request.¹³ The Court of Appeals for the Second Circuit affirmed the District Court's determination that the challenged delays violated the statute and upheld the District Court's remedial order. Day v. Schweiker, 685 F. 2d 19 (1982). We granted certiorari to consider whether it is appropriate for a federal court, without statutory authorization, to prescribe deadlines for agency adjudication of Title II disability claims and to order payment of interim benefits in the event of noncompliance. 461 U. S. 904 (1983).¹⁴ We conclude that the legislative history makes clear that Congress, fully aware of the serious delays in resolution of disability claims, has declined to impose deadlines on the administrative process. Accordingly, we vacate the judgment below.

II.

The Secretary does not challenge here the determination that § 405(b) requires administrative hearings to be held within a reasonable time. Nor does she challenge the District Court's determination that the delays encountered in the cases of plaintiffs Day and Maurais violated that requirement.¹⁵ She argues only that a statewide injunction that imposes judicially prescribed deadlines on HHS for all future disability determinations is contrary to congressional intent and constitutes an abuse of the court's equitable power. She argues in the alternative that even if the injunction is appropriate, the order requiring payment of interim benefits in cases of noncompliance is not. The Secretary looks primarily to legislative history to support both arguments.

A.

The Secretary correctly points out that Congress repeatedly has been made aware of the long delays associated with resolution of disputed disability claims and repeatedly has considered and expressly rejected suggestions that mandatory deadlines be imposed to cure that problem.¹⁶ She argues that Congress expressly has balanced the need for timely disability determinations against the need to ensure quality decisions in the face of heavy and escalating workloads and limited agency resources. In striking that balance, the Secretary argues, the relevant legislative history also shows that Congress to date has determined that mandatory deadlines for agency adjudication of disputed disability claims are inconsistent with achievement of the Act's primary objectives, and that the District Court's statewide injunction flatly contradicts that legislative determination. We find this argument persuasive.

Congressional concern over timely resolution of disputed disability claims under Title II began at least as early as 1975.¹⁷ It has inspired almost annual congressional debate since that time.¹⁸ The consistency with which Congress has expressed concern over this issue is matched by its consistent refusal to impose on the Secretary mandatory deadlines for resolution of disputed disability claims.

In 1975, the House Social Security Subcommittee held hearings on the delays encountered in resolving disputed Social Security claims,¹⁹ and 60 Members of the House sponsored a bill imposing statutory deadlines for each step in the administrative review of disputed SSA claims.²⁰ Expressions of concern were voiced in both the Senate and the House over the "huge backlog of some 103,000 cases awaiting hearing" before an ALJ. S. Rep. No. 94-550, p. 3 (1975); accord H. R. Rep. No. 94-679, pp. 1-2 (1975).²¹ Despite this concern, the Staff of the House Subcommittee advised against statutory deadlines because of the potential ...