Barnhart v. Thomas

Background

A 53-year-old woman who had worked six years as an elevator operator applied for disability insurance and Supplemental Security Income after her job was eliminated. She said heart disease and nerve problems left her unable to work. An administrative law judge found she had hypertension, a heart arrhythmia, and neck and back strain, but concluded she could still do her past job and denied benefits. The Appeals Council refused review and a district court affirmed. The Third Circuit, sitting en banc, reversed, saying the law clearly requires checking whether prior work exists in significant numbers nationwide.

Reasoning

The central question was whether the Social Security Administration must investigate whether a claimant’s prior job exists in significant numbers across the national economy before denying benefits. The SSA’s five-step rules assess the ability to do past work at step four and consider national job availability at step five. The Court applied the standard test for agency interpretations, found the statute ambiguous about whether the national-economy clause applies to past work, and held the SSA’s reading is a reasonable construction of the law. The Supreme Court reversed the Third Circuit and upheld the agency’s approach.

Real world impact

The ruling lets the SSA deny claims at the stage where a person can still perform prior work without separately proving that that job exists broadly in the economy. That makes claim processing faster but may disadvantage people whose former jobs have disappeared. The decision resolves a split among appeals courts and governs how the SSA evaluates disability claims nationwide.