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Barnhart v. Thomas

Facts

Pauline Thomas worked as an elevator operator for six years until her job was eliminated. In June 1996, at age 53, she applied for disability insurance benefits and Supplemental Security Income, claiming she was disabled due to heart disease and cervical and lumbar radiculopathy. After the SSA denied her application, she requested a hearing where the ALJ found that her impairments did not prevent her from performing her past work. The district court affirmed this decision, concluding that the existence of her old job was irrelevant under SSA regulations.

Pauline Thomas worked as an elevator operator for six years until her job was eliminated in August 1995. In June 1996, at age 53, Thomas applied for disability insurance benefits under Title II and Supplemental Security Income under Title XVI of the Social Security Act. She claimed that she suffered from, and was disabled by, heart disease and cervical and lumbar radiculopathy.

Issue

Whether the SSA may determine that a claimant is not disabled because she remains physically and mentally able to do her previous work, without investigating whether that previous work exists in significant numbers in the national economy.

The issue we must decide is whether the SSA may determine that a claimant is not disabled because she remains physically and mentally able to do her previous work, without investigating whether that previous work exists in significant numbers in the national economy.

Rule

Under the Social Security Act, a person qualifies as disabled only if his physical or mental impairment is of such severity that he is not only unable to do his previous work but cannot engage in any other kind of substantial gainful work which exists in the national economy.

Under the Social Security Act , the Social Security Administration (SSA) is authorized to pay disability insurance benefits and Supplemental Security Income to persons who have a 'disability.' A person qualifies as disabled, and thereby eligible for such benefits, 'only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy.' 42 U.S.C. 423(d)(2)(A) , 1382c(a)(3)(B).

Analysis

The court analyzed the statutory language and the SSA's interpretation, concluding that the clause 'which exists in the national economy' does not apply to 'previous work.' The SSA's regulations establish a five-step evaluation process for determining disability, where the inquiry into the national economy is reserved for the final step. The court found that the SSA's interpretation was reasonable and should be given effect.

As we held in Chevron U.S.A. Inc. v. NRDC, 467 U.S. 837, 843, 104 S. Ct. 2778, 81 L. Ed. 2d 694 (1984) , when a statute speaks clearly to the issue at hand we 'must give effect to the unambiguously expressed intent of Congress,' but when the statute 'is silent or ambiguous' we must defer to a reasonable construction by the agency charged with its implementation. The Third Circuit held that, by referring first to 'previous work' and then to 'any other kind of substantial gainful work which exists in the national economy,' 42 U.S.C. 423(d)(2)(A) (emphasis added), the statute unambiguously indicates that the former is a species of the latter. 294 F.3d at 572. We disagree.

Conclusion

The Supreme Court reversed the judgment of the circuit court, affirming the SSA's interpretation of the statute.

The Court reversed the judgment of the circuit court.

Who won?

The prevailing party was the Commissioner of Social Security, as the Supreme Court upheld the SSA's interpretation of the statute.

The prevailing party was the Commissioner of Social Security, as the Supreme Court upheld the SSA's interpretation of the statute.

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