Facts of the Case

The Social Security Act authorizes payment of Title II disability insurance benefits and Title XVI Supplemental Security Income to individuals who have an "inability to engage in any substantial gainful activity by reason of any medically determinable...impairment...which has lasted or can be expected to last for a continuous period of not less than 12 months." After developing a serious mental illness, Cleveland Walton lost his job as a teacher in October 1994. Eleven moths later, Walton was working as a cashier. When Walton applied for Title II disability insurance benefits and Title XVI Supplemental Security Income, the Social Security Administration denied him benefits, reasoning that his "inability" to engage in substantial gainful activity lasted only 11 months. The District Court affirmed. In reversing, the Court of Appeals held that the 12-month duration requirement modifies "impairment" not "inability," that no similar duration requirement relates to an "inability," and that, therefore, Walton was entitled to benefits despite regulations restricting them to those unable to work for 12 months. Further, the appellate court concluded that Walton qualified for benefits since, prior to his return to work, his "inability" would have been "expected" to last 12 months.

Question

Does the term "inability," in the Social Security Act, include a 12 month requirement, such that the inability must last, or must be expected to last, for at least 12 months? Is the term "expected to last" applicable only when the "inability" has not yet lasted 12 months?

Conclusion

Yes and yes. In a 9-0 opinion delivered by Justice Stephen G. Breyer, the Court held that the Social Security Administration's interpretations of the statute fell within its lawful interpretative authority. Justice Breyer noted that the Administration has determined in both its formal regulations and its interpretation of those regulations that an "inability" must last the same amount of time as an "impairment," or last or be expected to last not less than 12 months. "The statute's complexity, the vast number of claims that it engenders, and the consequent need for agency expertise and administrative experience lead us to read the statute as delegating to the Agency considerable authority to fill in, through interpretation, matters of detail related to its administration," concluded Justice Breyer.