Heckler v. Day
United States Supreme Court
467 U.S. 104 (1984)
Under Title II of the Social Security Act, disability claims went through a multi-step review process: an initial state agency determination, a request for reconsideration, an evidentiary hearing, and finally an appeal to the Department of Health and Human Services' Appeals Council. Leon Day (plaintiff) brought a class action challenging delays in the reconsideration and hearing stages of that process, after waiting 167 days for a reconsideration determination and 173 days for a hearing following his own requests. The district court found delays beyond 90 days at those stages unreasonable and issued an injunction requiring the Department to issue reconsideration decisions and hold hearings within 90 days; the Second Circuit affirmed. The Department (defendant) appealed, arguing the injunction contradicted congressional intent and exceeded the court's equitable powers.
Whether a federal court may impose fixed deadlines on the processing stages of Social Security disability claims when Congress has repeatedly considered, and expressly declined to enact, mandatory deadlines of its own.