Heckler v. Campbell
United States Supreme Court
461 U.S. 458 (1983)
Carmen Campbell, 52 years old with limited education and English proficiency, applied for Social Security disability benefits, claiming her bad back and hypertension prevented her from continuing work as a hotel maid. An administrative law judge (ALJ) found her back injury wasn't disabling on its own and that she retained the capacity for light physical work; relying on HHS's published medical-vocational guidelines, the ALJ then found a significant number of suitable jobs existed for someone of Campbell's age and abilities, and denied her claim. That denial was affirmed by the Social Security Appeals Council and the district court, but the Second Circuit reversed, holding the guidelines didn't provide specific enough evidence of actual alternative jobs available to Campbell and improperly deprived her of a chance to show she couldn't perform the noticed job categories. HHS appealed, and the Supreme Court granted certiorari to resolve a circuit split.
Whether the Secretary of Health and Human Services may rely on published medical-vocational guidelines, rather than individualized case-by-case testimony about specific available jobs, to determine a disability claimant's ability to find suitable work in the national economy.