Schweiker v. Chilicky

487 U.S. 412 (1988)

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Nature of the Case

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Facts

Under Title II of the Social Security Act, the federal government provides disability benefits to individuals who have contributed to the program and who have become unable to engage in gainful work because of physical or mental impairment. Congress enacted legislation requiring that most disability determinations be reviewed every three years. The Secretary of HHS initiated that review in March 1981. Under the CDR review, the individual bore the burden of demonstrating the continuing existence of a statutory disability. A denial of claims is reviewed, but benefits were usually terminated after a state agency found a claimant ineligible. Finding that benefits were too often being improperly terminated by state agencies only to be reinstated by a federal administrative law judge, Congress enacted emergency legislation in 1983 providing for a continuation of benefits pending review by an ALJ judge. To get an idea of what the scope of the problem was even the SSA itself reported that about 200,000 persons were wrongfully terminated and then reinstated between March 1981 and April 1984. Ps were three individuals whose disability benefits were terminated under the CDR program in 1981 and 1982. Two of them appealed their determinations through the administrative process and got benefits reinstated with retroactive reimbursement. The other party, Chilicky, instead filed a new application for benefits about 1.5 years after his benefits were initially stopped. That application was granted, and he was awarded one year’s retroactive payment. All Ps experienced many months in delay in getting the benefits they were entitled to, and all were wholly dependent on their disability benefits. They allege they were unable to maintain themselves or their families after they were declared ineligible. Chilicky was in the hospital recovering from open-heart surgery when he was informed that his heart condition was no longer disabling. Ps sued in federal court alleging that their due process rights were violated. They contended that Ds had adopted illegal policies that led to wrongful termination of benefits by state agencies. The District Court dismissed the case on the ground that Ps were protected by qualified immunity. Ps appealed pressing their claims for money damages against Ds in their individual capacities. The Ninth Circuit concluded that it couldn’t be determined as a matter of law that Ps could prove no state of facts that resulted in violations of their due process rights and consequent damages. They remanded the case for trial. Ds appealed to the Supreme Court, and it granted certiorari.