Sullivan v. Zebley
Encyclopedia
Sullivan v. Zebley, 493 U.S. 521
(1990), was a landmark decision
by the United States Supreme Court involving the determination of childhood Social Security
Disability benefits. In the decision, the Supreme Court ruled that substantial parts of the Supplemental Security Income
program's regulation on determining disability for children were inconsistent with the Social Security Act; particularly, the statutory standard of “comparable severity.” The suit highlighted what some felt was the need for a step in the evaluation of childhood disability claims that would be akin to the functional evaluation considered in many adult claims. It resulted in the addition of a consideration of functioning, and not merely medical severity, in children's SSI claims. The decision was rendered on February 20, 1990.
, Pennsylvania
. On July 12, 1983, plaintiff
s, including Zebley, filed a class action
complaint challenging the Social Security Administration
(SSA) listing-only policy of evaluating childhood disability claims. Community Legal Services of Philadelphia represented the plaintiffs; Richard Weishaupt argued the case and Jonathan Stein was co-lead counsel.
On July 16, 1986, the United States District Court for the Eastern District of Pennsylvania
granted, in part, the request of the Secretary of the HHS for summary judgment
. The district court dismissed the class action lawsuit.
The case was subsequently appealed to the United States Court of Appeals for the Third Circuit
. On August 10, 1988, the Third Circuit vacated
the district court's dismissal of the class complaint and remanded the case to district court. In doing this, the Third Circuit found that SSA’s interpretation of “comparable severity” was too restrictive and preclusive of an individualized assessment of children’s functional impairments. In response, on February 15, 1989, SSA filed a petition for a writ of certiorari requesting the Supreme Court’s review of the case.
Enrollment of disabled children on SSI dramatically increased following Zebley and its relaxation of SSA’s definition of disability for children. The case is noted as part of the trend of the liberalization of welfare benefits occurring at the time of the ruling.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1990), was a landmark decision
Landmark decision
Landmark court decisions establish new precedents that establish a significant new legal principle or concept, or otherwise substantially change the interpretation of existing law...
by the United States Supreme Court involving the determination of childhood Social Security
Social Security (United States)
In the United States, Social Security refers to the federal Old-Age, Survivors, and Disability Insurance program.The original Social Security Act and the current version of the Act, as amended encompass several social welfare and social insurance programs...
Disability benefits. In the decision, the Supreme Court ruled that substantial parts of the Supplemental Security Income
Supplemental Security Income
Supplemental Security Income is a United States government program that provides stipends to low-income people who are either aged , blind, or disabled. Although administered by the Social Security Administration, SSI is funded from the U.S. Treasury general funds, not the Social Security trust fund...
program's regulation on determining disability for children were inconsistent with the Social Security Act; particularly, the statutory standard of “comparable severity.” The suit highlighted what some felt was the need for a step in the evaluation of childhood disability claims that would be akin to the functional evaluation considered in many adult claims. It resulted in the addition of a consideration of functioning, and not merely medical severity, in children's SSI claims. The decision was rendered on February 20, 1990.
Background
The Zebley claim was originally denied by the state disability determination services (DDS) in HarrisburgHarrisburg, Pennsylvania
Harrisburg is the capital of Pennsylvania. As of the 2010 census, the city had a population of 49,528, making it the ninth largest city in Pennsylvania...
, Pennsylvania
Pennsylvania
The Commonwealth of Pennsylvania is a U.S. state that is located in the Northeastern and Mid-Atlantic regions of the United States. The state borders Delaware and Maryland to the south, West Virginia to the southwest, Ohio to the west, New York and Ontario, Canada, to the north, and New Jersey to...
. On July 12, 1983, plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
s, including Zebley, filed a class action
Class action
In law, a class action, a class suit, or a representative action is a form of lawsuit in which a large group of people collectively bring a claim to court and/or in which a class of defendants is being sued...
complaint challenging the Social Security Administration
Social Security Administration
The United States Social Security Administration is an independent agency of the United States federal government that administers Social Security, a social insurance program consisting of retirement, disability, and survivors' benefits...
(SSA) listing-only policy of evaluating childhood disability claims. Community Legal Services of Philadelphia represented the plaintiffs; Richard Weishaupt argued the case and Jonathan Stein was co-lead counsel.
On July 16, 1986, the United States District Court for the Eastern District of Pennsylvania
United States District Court for the Eastern District of Pennsylvania
The United States District Court for the Eastern District of Pennsylvania is one of the original 13 federal judiciary districts created by the Judiciary Act of 1789...
granted, in part, the request of the Secretary of the HHS for summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
. The district court dismissed the class action lawsuit.
The case was subsequently appealed to the United States Court of Appeals for the Third Circuit
United States Court of Appeals for the Third Circuit
The United States Court of Appeals for the Third Circuit is a federal court with appellate jurisdiction over the district courts for the following districts:* District of Delaware* District of New Jersey...
. On August 10, 1988, the Third Circuit vacated
Vacated judgment
A vacated judgment makes a previous legal judgment legally void. A vacated judgment is usually the result of the judgment of an appellate court which overturns, reverses, or sets aside the judgment of a lower court....
the district court's dismissal of the class complaint and remanded the case to district court. In doing this, the Third Circuit found that SSA’s interpretation of “comparable severity” was too restrictive and preclusive of an individualized assessment of children’s functional impairments. In response, on February 15, 1989, SSA filed a petition for a writ of certiorari requesting the Supreme Court’s review of the case.
Court's opinion
After oral arguments on November 28, 1989, the Supreme Court issued its decision on February 20, 1990. By a 7 to 2 margin, the Supreme Court found SSA’s listing-only methodology for determining SSI child claims inconsistent with the statutory standard of “comparable severity” set forth in the Social Security Act. The Court invalidated the SSA's regulations and rulings as they were found to not provide SSI child claimants with an individualized functional assessment similar to the functional analysis considered in many adult claims. The Court concluded that SSA could determine the effect of an impairment on a child’s ability to perform age-appropriate activities in much the same way it determines the effect of impairments on an adult’s ability to work.Impact of decision
Prior to Zebley, a child would only be found disabled under the SSA's definition if he or she met or equaled one of SSA’s listings of impairments. Following the ruling, the childhood definition of disability was changed to having “an impairment resulting in marked and severe functional limitations.”Enrollment of disabled children on SSI dramatically increased following Zebley and its relaxation of SSA’s definition of disability for children. The case is noted as part of the trend of the liberalization of welfare benefits occurring at the time of the ruling.
See also
- Supplemental Security IncomeSupplemental Security IncomeSupplemental Security Income is a United States government program that provides stipends to low-income people who are either aged , blind, or disabled. Although administered by the Social Security Administration, SSI is funded from the U.S. Treasury general funds, not the Social Security trust fund...
- List of class action lawsuits
- List of United States Supreme Court cases, volume 493
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court