In the case of Richardson, Secretary of Health, Education, and Welfare v. Perales in 1970, the U.S Supreme Court ruled that written reports from a doctor could be used as substantial evidence to deny disability benefits under the Social Security Act. The plaintiff was Luis Perales who claimed he was disabled and unable to work due to back pain and other ailments. However, his claim for social security disability insurance benefits was denied based on medical reports submitted by doctors appointed by the state agency which contradicted his claims. He argued that using these reports without giving him an opportunity to cross-examine those doctors violated his rights under the Sixth Amendment's Confrontation Clause. The court held in a 9-0 decision that such use did not violate any constitutional right because administrative proceedings are not bound by all courtroom procedures or evidentiary rules applicable in trials; they only need satisfy fundamental requirements of fairness. Furthermore, it noted that there were sufficient procedural safeguards present including opportunities for rebuttal and questioning before an impartial decision-maker (an examiner). This ruling established precedent regarding admissibility standards within administrative hearings versus traditional court settings.

In the dissenting opinion for Richardson, Secretary of Health, Education and Welfare v. Perales (1970), Justice Hugo Black argued that the use of written reports by non-testifying physicians to determine disability benefits was a violation of an individual's right to confront witnesses against them as guaranteed by the Sixth Amendment. He contended that these reports were hearsay evidence and should not be admissible in court proceedings without cross-examination. Furthermore, he believed that this practice denied claimants due process under law because it did not provide them with a fair opportunity to challenge or rebut medical opinions used against their claims. In essence, Justice Black felt strongly about upholding constitutional rights even within administrative procedures such as social security hearings.