Term: 2003
Docket: 02-763
Jo Anne B. Barnhart, Commissioner Of Social Security v. Pauline Thomas
- Pro
02-763 BARNHART v. THOMAS Ruling below: CA 3, 294 F.3d 568. QUESTION PRESENTED Titles II and XVI of the Social Security Act define disability as the "inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months." 42 U.S.C. 423(d)(1)(A); 42 U.S.C. 1382c(a)(3)(A). The Act further provides that a claimant "shall be determined to be under a disability only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy." 42 U.S.C. 423(d)(2)(A); 42 U.S.C. 1382c(a)(3)(B). Under the Act, "work which exists in the national economy" means "work which exists in significant numbers either in the region where such individual lives or in several regions in the country ." 42 U.S.C. 423(d)(2)(A); 42 U.S.C. 1382c(a)(3)(B). The question presented is: Whether the Commissioner of Social Security may determine that a claimant is not "disabled" within the meaning of the Act because the claimant remains physically and mentally able to do her previous work, without considering whether that particular job exists in significant numbers in the national economy. CERT. GRANTED: 2/24/03
In the case of Jo Anne B. Barnhart, Commissioner of Social Security v. Pauline Thomas, 2003, the U.S Supreme Court ruled in favor of Thomas who was initially denied disability benefits by the Social Security Administration (SSA). The SSA had argued that since she could perform her past relevant work as it is generally performed in the national economy, she was not disabled under their rules. However, Thomas contended that due to her physical impairments and limitations from a stroke and heart disease she couldn't do her previous job as an elevator operator because it required standing for long periods which exceeded her residual functional capacity (RFC). The court held that when determining whether an individual can engage in past relevant work under step four of its sequential evaluation process for disability claims, SSA must consider how this work is actually performed by this particular individual rather than how it's typically done in general across the national economy.
In the dissenting opinion for Barnhart v. Thomas, Justice Souter argued that the majority's interpretation of Social Security Act was incorrect and unfair to claimants like Pauline Thomas who are unable to perform their previous work due to disability but can do other jobs only if they exist in significant numbers in the national economy. He contended that a job existing in significant numbers either regionally or nationally should be relevant only when it is determined whether an individual could make an adjustment to other work given his age, education, and skills. The majority’s decision would mean that even if there were very few jobs available nationwide which a person could adjust to considering her residual functional capacity (RFC), she would still not be considered disabled under SSA rules. This approach according to him contradicts Congress' intent behind enacting this law - providing income security for those who cannot engage in substantial gainful activity because of physical or mental impairment.
