Nash v. Bowen
United States Court of Appeals for the Second Circuit
869 F.2d 675 (1989)
Facing a massive case backlog, the Social Security Administration's Office of Hearings and Appeals, acting on behalf of Secretary Otis Bowen (defendant), instituted a peer-review program, monthly production goals, and a quality-assurance program limiting reversals of benefit denials; Simon Nash (plaintiff), an administrative-law-judge-in-charge who complained about these reforms, was demoted to an ordinary ALJ and sued, alleging the reforms unlawfully interfered with ALJs' decisional independence under the Administrative Procedure Act. After a bench trial, the district court found the reforms did not improperly curtail that independence and dismissed Nash's claims, prompting his appeal.
Whether, under administrative law, a federal agency may impose reform measures to increase the efficiency of its administrative law judges.