Heckler v. Campbell

Background

A hotel housekeeper, Carmen Campbell, applied for Social Security disability benefits because of a bad back and high blood pressure. An administrative judge found she could do "light work," applied the agency’s published medical‑vocational guidelines, and concluded that many jobs fit her age, education, and experience, so she was not disabled. The Appeals Council and a federal district court agreed, but the Second Circuit reversed, saying the agency had to identify specific jobs the claimant could do.

Reasoning

The Supreme Court addressed whether the Secretary of Health and Human Services may rely on published job‑guideline rules (the medical‑vocational “grids”) instead of requiring a vocational expert at every hearing. The Court held that the statute gives the Secretary broad rulemaking authority and that the grids fairly resolve the general factual question of what kinds and numbers of jobs exist in the national economy. The Court emphasized that individualized findings about a claimant’s limits must still be made at the hearing and that claimants can show the grids do not apply to them. On the record before the Court, the guidelines were not arbitrary or beyond the Secretary’s authority.

Real world impact

The decision allows the Social Security Administration to use standardized grids to decide many disability claims more efficiently and uniformly, reducing routine reliance on expert testimony. Claimants retain the right to a full hearing and may present evidence that their specific limitations make the grid inapplicable. The Court reversed the appeals court and restored the agency’s use of the guidelines.

Dissents or concurrances

Justice Brennan stressed the judge’s strong duty to develop the record, especially for unrepresented claimants with limited English. Justice Marshall agreed the grids are valid but would have sent the case back for a fuller hearing to test whether the judge had adequately explored Campbell’s limitations.