Heckler v. Day

Background

A class of Vermont residents, led by Leon Day and Amedie Maurais, sued after long delays in getting reconsideration decisions and hearings on Social Security disability claims. The District Court found delays over 90 days unreasonable, certified a statewide class, and ordered the Department of Health and Human Services to complete reconsiderations and hold hearings within 90 days and to pay interim benefits when deadlines were missed. The Court of Appeals affirmed that relief.

Reasoning

The Supreme Court reviewed whether federal courts may impose such statewide timetables and require interim payments. The majority relied on legislative history showing Congress was repeatedly aware of delays but consistently declined to enact mandatory deadlines, prioritizing decision quality and uniform administration. The Court concluded that broad judicially imposed deadlines for Title II disability claims would conflict with Congress’s clear intent and would be an improper judicial intrusion.

Real world impact

The Court vacated the Vermont injunction and sent the case back for further proceedings. Classwide orders that set mandatory deadlines or compel interim payments are no longer an available nationwide or statewide remedy when Congress has declined to adopt such rules. The decision leaves room for courts to remedy individual statutory violations and for Congress or the agency to adopt time limits if they choose.

Dissents or concurrances

Justice Marshall, joined by three Justices, dissented, arguing the District Court’s 90-day remedy was narrowly tailored, grounded in the factual record, limited to Vermont, and feasible without harming decision quality or shifting resources across States.