Barnhart v. Walton
The Supreme Court upheld the Social Security Administration's rules for deciding disability claims, ruling that the agency can require a person's inability to work to last a full 12 months, and can use hindsight to deny benefits when someone actually returns to work before that year is up.
The decision resolves a split among federal appeals courts over how strictly to read the disability statute, and it preserves an agency approach the government said would have cost billions of dollars if struck down.
“Courts grant an agency's interpretation of its own regulations considerable legal leeway.”
Explaining why the Social Security Administration's reading of its own regulation deserved deference.
How it got here: A federal trial court upheld the agency's denial; the Fourth Circuit reversed; the government asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Cleveland Walton, a schoolteacher, developed schizophrenia and depression in October 1994 and lost his job. He returned to part-time work as a cashier by mid-1995 and full-time work by December 1995 — about 11 months after becoming unable to work. The Social Security Administration denied his disability claim because his inability to work lasted only 11, not 12, months.
The question before the Court
When someone applying for Social Security disability benefits goes back to work after 11 months, can the government simply deny benefits without asking whether the disability might have been expected to last a full year?
Why it matters
Disability applicants who return to work in under 12 months generally cannot get benefits, even if their condition might otherwise have been expected to last longer. The ruling keeps the Social Security Administration's existing claims process intact, avoiding roughly $80 billion in additional costs the government said a contrary ruling would have caused over ten years.
What changes now
The Fourth Circuit's ruling in Walton's favor is reversed, meaning his claim for benefits is rejected under the agency's existing rules. The decision resolves the underlying legal question for future cases nationwide, confirming that the Social Security Administration may require a full 12-month inability to work and may use hindsight rather than speculative predictions when someone actually returns to work early.
Concurrences and dissents
Concurrence — Justice Scalia
Justice Scalia agreed with the outcome and with Part III of the opinion, but declined to join Part II's discussion crediting the agency's older, informal interpretations (a 1982 ruling, a 1965 manual, and a 1957 letter) with 'particular deference' based on their age. He argued that once Chevron accepts a range of permissible readings, an interpretation's age should not matter, and that if the Court wanted to rely on the older materials it should have explained why they were authoritative enough under Mead to deserve deference.
How the Court got there
The legal reasoning, step by step
- The Court applied the two-step framework from Chevron U.S.A. Inc. v. Natural Resources Defense Council: first ask whether the statute unambiguously resolves the question, and if not, defer to the agency's interpretation as long as it is reasonable.
- The Court found the statute ambiguous about whether the 'inability to work' itself, as opposed to just the underlying medical impairment, must last 12 months, because the statutory text was silent on the point and a nearby provision supported reading the two requirements as equivalent.
- Because the statute allowed for the agency's reading, and because the agency's interpretation reasonably supplied a needed duration requirement consistent with the statute's structure and the agency's long-standing practice, the Court held the 12-month inability requirement was a lawful interpretation.
- On the second question, the Court found the statute similarly ambiguous about whether the agency, deciding after the fact, must consider what might hypothetically have been expected before a claimant's actual return to work.
- The Court reasoned that requiring the agency to answer a speculative, contrary-to-fact question about the past would be unworkable, and that using the claimant's actual return to work as a reasonable stand-in for that speculation was a permissible way to administer a complex statute.
- The Court concluded that the agency's practice of using hindsight to deny a 'trial work period' when a claimant actually returned to work within 12 months was therefore a lawful exercise of its interpretive authority.
Doctrinal impact
Cases affected by this decision
Reaffirms Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. (467 U.S. 837)
The Court relies on Chevron's two-step framework as the basis for deferring to the agency's interpretation.
Limits Christensen v. Harris County (529 U.S. 576)
The Court clarifies that any suggestion in Christensen of an absolute notice-and-comment requirement was rejected by Mead.