After a heart attack left her unable to continue working as a housekeeper in the late 1980s, Pauline Thomas took a job as an elevator operator. By the mid-1990s, however, Thomas's job and others like it were eliminated as elevators became automated. Thomas applied for Social Security disability benefits because she could not do other work. The Social Security Administration (SSA), however, rejected her claim because, it said, she was still able to perform the duties of her former position. The fact that it was nearly impossible to find such a position, the SSA held, did not entitle her to benefits under disability law. An administrative judge and a federal district court both upheld the SSA's position, but the Third Circuit Court of Appeals reversed, holding that "a claimant's previous work must be substantial gainful work which exists in the national economy."
Are persons eligible for Social Security disability benefits if they are still able to perform their jobs, but the jobs no longer exists in meaningful numbers in the national economy?
No. In a unanimous opinion authored by Justice Antonin Scalia, the Court held that the SSA's decision had been a reasonable interpretation of the statute and was therefore entitled to deference under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837. Justice Scalia wrote, "The proper Chevron inquiry is not whether an agency construction can give rise to undesirable results... but whether... the agency construction is reasonable. Here, the SSA's authoritative decision satisfies that test."
Decisions
Decision: 9 votes for Barnhart, 0 vote(s) against Legal provision: Social Security, as amended, including Social Security Disability Benefits Reform Act, but excluding Medicare, Medicaid, Supplemental Security Income, and Aid to Families with Dependent Children
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Full Opinion by Justice Antonin Scalia
