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Administrative Law Keyed to Mawshaw
Heckler v. Campbell
Citation:
461 U.S. 458 (1983)Facts
Carmen Campbell, born in Panama with limited education and English proficiency, worked as a hotel maid until 1979 when she applied for disability benefits due to a back condition and hypertension. 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 previous work as a maid, she retained the physical capacity to perform “light work.” The ALJ found that Campbell was 52 years old, had limited education, could understand and read English fairly well despite difficulties speaking and writing it, and had previous employment consisting of unskilled jobs. Applying the medical-vocational guidelines, the ALJ concluded that a significant number of jobs existed that a person with Campbell’s qualifications could perform, and therefore she was not disabled. The Social Security Appeals Council and the District Court affirmed this determination, but the Second Circuit reversed, holding that the Secretary must identify specific alternative jobs that Campbell could perform.
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