Facts of the Case

Title II of the Social Security Act (Act) establishes a four-step review process of disputed disability benefit claims. First, a state agency determines if a claimant has a disability and when the condition began or ended. Second, state agencies' disability determinations can be reviewed upon the claimant's request. Third, if upon review the claimant suffers an adverse finding he or she may demand an evidentiary hearing by an administrative law judge. Fourth, if a claimant is dissatisfied with the administrative law judge's decision, they may appeal to the Appeals Council of the Department of Health and Human Services (HHS). Claiming delays in excess of 90 days, during steps two and three, Leon Day sued on behalf of several similarly aggrieved Vermont claimants alleging a violation of the "reasonable time" hearing limitation. On appeal from the Second Circuit Court of Appeal's ruling upholding a district court's imposition of disability hearing deadlines, the Supreme Court granted HHS Secretary Margaret Heckler certiorari.

Question

Does the judiciary's imposition of deadlines by which disability claims must be processed constitute an unconstitutional interference with a legislatively mandated statute?

Conclusion

Yes. In a 5-to-4 opinion, the Court held that Congress already considered and expressly rejected the imposition of mandatory disability dispute-resolution deadlines. Such deadlines, according to congressional reports, would subordinate quality of service to timeliness. The Court cautioned that pervasively regulated areas, such as the Social Security Act in general and its dispute resolution mechanisms in particular, should be left free of judicial intervention that is far less attuned to the needs of the constituencies served by such legislation.