Constance v. Secretary of Health & Human Services

2 Mass. Supp. 281
CourtDistrict Court, D. Massachusetts
DecidedMarch 9, 1981
DocketCiv. A. No. 76-3304-F
StatusPublished

This text of 2 Mass. Supp. 281 (Constance v. Secretary of Health & Human Services) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Constance v. Secretary of Health & Human Services, 2 Mass. Supp. 281 (D. Mass. 1981).

Opinion

MEMORANDUM

FREEDMAN, D.J.

This is an action under Section 1631(c)(3) of the Social Security Act, 42 U.S.C. § 1383(c)(3), to review a final decision of the Secretary. The jurisdiction of this Court is found in Section 205(g) of the Social Security Act, 42 U.S.C. §405(g). The plaintiff also claims a cause of action under 42 U.S.C. §1983 against the Commissioner of the Massachusetts Department of Public Welfare. Jurisdiction over that claim rests on 28 U.S.C. §1343. The'matter is presently before the Court on cross-motions for summary judgment.

I. BACKGROUND

The gravamen of plaintiffs complaint is that, in calculating benefits, the Secretary has failed to take proper account of the presence of an essential person in the household. Resolution of this claim requires an analysis of the interrelation of several statutory provisions.

A. Statutory Schemes

Plaintiff has been determined to be dis[283]*283abled since January of 1973. During 1973 he received benefits under Title XIV of the Social Security Act, Aid to the Permanently and Totally Disabled (APTD). 42 U.S.C. §§1351-1355 (repealed by P.L. 93-603 eff. Jan. 1, 1974). This program was administered by the Commonwealth of Massachusetts. Mass. Gen. Laws c. 118D (repealed Jan. 1, 1974). The benefits paid to plaintiff included an “essential person” allowance for his wife, Sydonia Constance. The essential person allowance is available where a person who is not eligible for benefits in his or her own right lives with and is considered essential to the welfare of someone who is eligible for benefits.

On January 1, 1974 the APTD program was replaced by Title XVI of the Social Security Act, Supplemental Security Income (SSI). 42 U.S.C. §§1381-1394. Plaintiffs APTD eligibility was converted into SSI eligibility at that time.

The SSI program differs from the old APTD program in several respects, most notably by transferring operational responsibility from the states to the Social Security Administration and by defining a minimum level of benefits. See, 42 U.S.C. § 1382. Subsequent to enactment of Title XVI, but prior to its effective date, Congress separately addressed the treatment to be accorded individuals who were at the time of conversion receiving additional payments for support of an essential person. P.L. 93-66, §211 as amended P.L. 93-233, § § 4(a)(2), (b)(3). Section 211 authorized the continuation of essential person benefits for individuals who received such benefits under APTD as of December 1973 (the final APTD grant before the effective date of SSI). Apart from this saving or “grandfather” provision, SSI does not provide for essential persons. Because Sydonia Constance had previously qualified for essential person status (under APTD), the plaintiffs benefits (under SSI) therefore included the statutory minimum-benefits, 42 U.S.C. § 1382, as well as essential person benefits, P.L. 93-66, §211 as amended. For purposes of the instant motions, there is no question of plaintiffs original eligibility for benefits from each source.

Plaintiffs unhappiness stems from the manner in which benefits under a correlative state program of SSI supplementation have been calculated. Again, there is no question of his rights to such benefits, but rather a dispute as to the amounts he is due in view of his receipt of essential person benefits.

Title XVI provides for two types of state supplementation of SSI — optional and mandatory. Under the optional program, the Social Security Administration excludes state payments to eligible individuals from the calculation of income, thereby permitting each state to provide its residents with benefits above the federal floor. 42 U.S.C. §1382.e(a). The mandatory supplementation program was subsequently enacted to ensure that SSI benefits are at least as great as benefits previously received under APTD. P.L. 93-66, § 212 as amended P.L. 93-233, § 10. The Massachusetts supplementation program was created by Mass. Gen. Law, c. 118A,- § 1.

B. Review Process

On May 9, 1975 plaintiff was notified that his SSI benefits would be reduced because he was also receiving Title II benefits and was therefore less needy. Plaintiff followed appropriate administrative remedies to contest this determination, and was afforded a hearing on July 7,1975. The Hearing Examiner determined that plaintiff had in fact received excessive SSI benefits, in light of the fact that he had also received Title II benefits. Transcript at 14-32.

In the course of reaching his determination of overpayment, it appeared to the Hearing Examiner that, while plaintiff had been overpaid through SSI, he had in fact been underpaid through the Massachusetts optional supplementation program. Transcript at 22-25. The Massachusetts Agreement with the United States Department of Health, Education and Welfare, pursuant to 42 U.S.C. §1382e, does not set out a separate category for an eligible individual living with an essential person. See, Transcript at 177-213. The Hearing Examiner noted that in view of this omission, the [284]*284State-Federal Agreement was susceptible to at least two interpretations. “Either the amount of optional State supplemental benefits for an individual remains the same whether an essential person is present or not, or the total amount of State and Federal benefits remains constant.” Transcript at 22.

In practical terms, the distinction translates into the following benefits for the representative month of January 1974, when plaintiff received a total of $214.90, the Massachusetts minimum benefit for an individual. St. 1973, c. 1210, §35; see, Mass. Gen. Laws, c. 118A, §1, note.

This total represents plaintiffs combined . federal benefit of $210.00, to which Massachusetts has added $4.90 under the optional supplementation program. In other words, the latter interpretation propounded by the Hearing Examiner has been employed, apd plaintiffs total federal and state benefits remain constant.

The Hearing Examiner felt, however, that reliance on a constant total method was misplaced under the facts of this case. Such a method resulted in plaintiff, a qualified individual living with an essential person, receiving no greater benefits than a qualified individual living alone. Recognizing that the state supplementation for a qualified individual living alone would be $74.90, the Hearing Examiner reasoned that the same benefit should be paid to a qualified individual in plaintiff’s situation.

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Bluebook (online)
2 Mass. Supp. 281, Counsel Stack Legal Research, https://law.counselstack.com/opinion/constance-v-secretary-of-health-human-services-mad-1981.