In Heckler, Secretary of Health and Human Services v. Campbell (1982), the U.S. Supreme Court ruled that the Social Security Administration could use general medical-vocational guidelines to determine disability benefits eligibility without considering individual vocational factors for each applicant. The case was brought by a disabled worker who argued that her specific skills and experience were not adequately considered in denying her benefits under these guidelines. However, the court held 9-0 that while an individual's capabilities must be considered when determining whether they can do their previous work, it is not necessary to individually assess every claimant’s ability to perform other types of work available in the national economy.

In the dissenting opinion for Heckler v. Campbell, it was argued that the Secretary of Health and Human Services' reliance on medical-vocational guidelines (the "grids") to determine disability benefits eligibility without considering individual vocational factors was inappropriate. The dissent emphasized that Congress intended for a personalized assessment when determining whether an individual can engage in any other kind of substantial gainful work existing in significant numbers in the national economy. It was also pointed out that using grids as conclusive evidence fails to consider many real-world employment variables such as job availability, employer hiring practices or reasonable commuting distance. Furthermore, they criticized how these grids were developed - based largely on theoretical assumptions rather than empirical data about jobs available to people with various impairments and functional limitations.