, was a case heard before the
United States Supreme Court concerning whether the
United States Secretary Of Health And Human Services could rely on published medical-vocational guidelines to determine a claimant’s right to Social Security benefits.
In 1978, the Secretary of Health and Human Services promulgated regulations in order implement the statutory definition of : physical ability, age, education, and work experience. Information was also compiled about what jobs were available.
Carmen Campbell claimed she had a back condition that kept her from working at her former job as a hotel
Maid . Ms. Campbell had been born in
Panama , and though she had limited ability to speak and write
English , she could read and understand English fairly well. The Administrative Law Judge in her case found that by using the guidelines, there were a significant number of jobs that existed that Ms. Campbell could perform and concluded that she was not disabled.
Ms. Campbell's case was appealed to the
United States Court Of Appeals For The Second Circuit which reversed saying that the guidelines did not provide evidence that specific alternative jobs existed, the determination that Ms. Campbell was disabled was not supported by substantial evidence as required by the
Social Security Act .
In an opinion delivered by
Justice Powell , the Supreme Court reversed the Second circuit saying that “
{Link without Title} here the statute expressly entrusts the Secretary with the responsibility for implementing a provision by regulation, review is limited to determining whether the regulations promulgated exceeded the Secretary’s statutory authority and whether they are arbitrary and capricious.” The court decided that even where an agency's enabling statute expressly required that it hold a hearing, the agency could rely on its rulemaking authority to determine issues that didn't require case-by-case considerations.
The court held that the Secretary’s reliance on the guidelines were not inconsistent with the
Social Security Act , or that they were arbitrary and capricious.
Justice Brennan concurred but pointed out that the record contained very little evidence about Campbell's ability to do "light work."
Justice Marshall dissented essentially on the same ground.
