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Administrative Law Keyed to Breyer
Heckler v. Campbell
Citation:
461 U.S. 458 (1983)Facts
Carmen Campbell, a 52-year-old woman born in Panama with limited education and English proficiency, worked as a hotel maid until a back condition and hypertension prevented her from continuing. In 1979, she applied for Social Security disability benefits. After her application was denied, she requested a hearing before an Administrative Law Judge. The ALJ determined that while Campbell’s back condition prevented her from returning to her work as a maid, she retained the physical capacity to perform “light work.” Using the medical-vocational guidelines, which consider a claimant’s age, education, work experience, and residual functional capacity, the ALJ concluded that a significant number of jobs existed in the national economy that Campbell could perform. The ALJ did not identify specific jobs Campbell could perform, nor did he call a vocational expert to testify. Campbell’s application was denied, and this denial was upheld by both the Social Security Appeals Council and the District Court. The Court of Appeals for the Second Circuit reversed, holding that the Secretary must identify specific alternative jobs that the claimant could perform. The Supreme Court granted certiorari to resolve a conflict among the Courts of Appeals regarding the validity of the Secretary’s reliance on medical-vocational guidelines.
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