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Astrue v. Capato ex rel. B.N.C., 566 U.S. 541, 132 S.Ct. 2021, 182 L.Ed.2d 887, 80 USLW 4369, 179 Soc.Sec.Rep.Serv. 10, Unempl.Ins.Rep. (CCH) P 14965C, 12 Cal. Daily Op. Serv. 5426, 2012 Daily Journal D.A.R. 6514, 23 Fla. L. Weekly Fed. S 308

Facts

Karen Capato and Robert Capato were married in 1999, and Robert was diagnosed with cancer shortly thereafter. Before undergoing treatment that could render him sterile, Robert deposited his sperm in a sperm bank. After Robert's death in March 2002, Karen used the frozen sperm to conceive twins, who were born in September 2003. Karen applied for Social Security survivors benefits for the twins, but the Social Security Administration denied her application, stating that the twins could only qualify for benefits if they could inherit from Robert under Florida's intestacy law, which did not recognize posthumously conceived children as eligible heirs.

Karen Capato married Robert Capato in May 1999. Shortly thereafter, Robert was diagnosed with esophageal cancer and was told that the chemotherapy he required might render him sterile. Because the couple wanted children, Robert, before undergoing chemotherapy, deposited his semen in a sperm bank, where it was frozen and stored.

Issue

Whether the twins conceived posthumously are entitled to Social Security survivors benefits under the Social Security Act, given that they cannot inherit from their deceased father under Florida's intestacy law.

To resolve this case, we must decide whether the Capato twins rank as “child [ren]” under the Act's definitional provisions.

Rule

Under 42 U.S.C. § 416(h)(2)(A), the determination of whether an applicant is a child of an insured individual for purposes of Social Security benefits requires applying the intestacy law of the insured individual's domiciliary state.

In determining whether an applicant is the child … of [an] insured individual for purposes of this subchapter, the Commissioner of Social Security shall apply [the intestacy law of the insured individual's domiciliary State].

Analysis

The Supreme Court analyzed the relevant provisions of the Social Security Act and determined that the Social Security Administration's interpretation, which requires that a child must be able to inherit under state intestacy law to qualify for benefits, was reasonable and entitled to deference. The Court found that the SSA's reading aligned with the statute's purpose of providing benefits primarily to those who were dependent on the deceased wage earner during their lifetime. The Court rejected the Third Circuit's interpretation that biological children of married couples automatically qualify for benefits without regard to intestacy law.

The SSA's reading is better attuned to the statute's text and its design to benefit primarily those supported by the deceased wage earner in his or her lifetime.

Conclusion

The Supreme Court reversed the Third Circuit's decision and held that the twins were not entitled to Social Security survivors benefits because they could not inherit from their father under Florida law. The case was remanded for further proceedings consistent with this opinion.

We conclude that the SSA's reading is better attuned to the statute's text and its design to benefit primarily those supported by the deceased wage earner in his or her lifetime.

Who won?

The Social Security Administration prevailed in the case because the Supreme Court upheld its interpretation of the Social Security Act, which requires that a child must qualify for inheritance under state intestacy law to be eligible for benefits.

The SSA's longstanding interpretation, set forth in regulations published after notice-and-comment rulemaking, is neither “arbitrary or capricious in substance, [n]or manifestly contrary to the statute.”

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