Morris v. Weinberger, Secretary of Health, Education, and Welfare

Background

A father sought Social Security disability benefits for his adopted daughter but was denied because the adoption had not been supervised by a child-placement agency. The Court had agreed to review the case, but while review was pending Congress amended the Social Security rule at issue and changed which adopted children qualify for benefits.

Reasoning

The Court’s per curiam decision dismissed the previously granted review as improvidently granted after Congress enacted the Social Security Amendments of 1972, which altered §202(d)(8). Because Congress changed the statutory rule soon after certiorari was allowed, the Court declined to decide the legal challenge to the old statute and did not reach the merits.

Real world impact

The dismissal means the Supreme Court did not rule on whether the earlier distinction among types of adoption supervision was lawful, so the petitioner's underlying claim remains unresolved by this Court. The new statute removes the old agency-supervision requirement but adds a different rule requiring that an adopted child have lived with the beneficiary for the year before the beneficiary’s disability began. That new rule does not help this petitioner, who began receiving disability benefits long before his adopted daughter was born.

Dissents or concurrances

Justice Douglas dissented, arguing the Court should decide the merits because the new Act does not benefit this petitioner and the old statute may still apply to his pre-October 1972 application, so the constitutional claim should be reached by the Court.