Mental Health Association of Minnesota v. Heckler

720 F.2d 965
CourtCourt of Appeals for the Eighth Circuit
DecidedNovember 4, 1983
Docket83-1263
StatusPublished
Cited by23 cases

This text of 720 F.2d 965 (Mental Health Association of Minnesota v. Heckler) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mental Health Association of Minnesota v. Heckler, 720 F.2d 965 (8th Cir. 1983).

Opinion

720 F.2d 965

3 Soc.Sec.Rep.Ser. 183, Unempl.Ins.Rep. CCH 15,036
MENTAL HEALTH ASSOCIATION OF MINNESOTA, and H.C., K.F.,
J.M., and C.A., on behalf of themselves and others
similarly situated, Appellees,
v.
Margaret M. HECKLER, Secretary of the United States
Department of Health and Human Services, Appellant.

No. 83-1263.

United States Court of Appeals,
Eighth Circuit.

Submitted June 16, 1983.
Decided Nov. 4, 1983.

James M. Rosenbaum, U.S. Atty., Mary L. Egan, Asst. U.S. Atty., Minneapolis, Minn., Donald A. Gonya, Asst. Gen. Counsel, Dept. of Health and Human Services, Randolph W. Gaines, Deputy Asst. Gen. Counsel for Litigation, A. George Lowe, Chief, Disability Litigation Branch, Gabriel L. Imperato, Social Security Division Dept. of Health and Human Services, Baltimore, Md., for appellant.

Mark A. Bohnhorst, Litigation Coordinator, Martha A. Eaves, Southern Minnesota Regional Legal Services, Inc., St. Paul, Minn., William Messinger, Messinger, Cooper & Norton, Minneapolis, Minn., for Mental Health Association of Minnesota, Leonard S. Rubenstein, Jane Bloom Yohalem, Mental Health Law Project, Washington, D.C., Co-Counsel, for appellees.

Anthony Celebrezze, Jr., Atty. Gen., State of Ohio, Columbus, Ohio, Frank J. Kelley, Atty. Gen., State of Mich., Lansing, Mich., Hubert H. Humphrey III, Atty. Gen., State of Minn., P. Kenneth Kohnstamm, Sp. Asst. Atty. Gen., St. Paul, Minn., amici curiae for appellees.

Before LAY, Chief Judge, SWYGERT,* Senior Circuit Judge, and ARNOLD, Circuit Judge.

LAY, Chief Judge.

The Secretary of Health and Human Services appeals from the district court order1 granting the plaintiffs' motion for a preliminary injunction. The underlying dispute before the district court is a class action challenging the procedure used by the Secretary in disability determinations of the severely mentally ill in Region V.2 See 42 U.S.C. Secs. 401-431 (1976 & Supp. V 1981) (Social Security Disability Insurance (SSDI) benefits for disabled workers; 42 U.S.C. Secs. 1381-1383 (1976 & Supp. V 1981) (Supplemental Security Income (SSI) for the Aged, Blind, and Disabled).3 The plaintiffs contend that the substantive standards employed by the Secretary in disability determinations did not comply with the relevant statutory and regulatory procedures.

In issuing the preliminary injunction, the district court enjoined the Secretary from employing a presumption that an individual whose mental impairment is not as severe as those contained in the Listing of Impairments4 is capable of performing at least unskilled work. Additionally, the Order required the Secretary inter alia to review the claims of all class members whose claims were denied or whose benefits were terminated on or after March 1, 1981. Moreover, in making disability determinations, the Secretary is required to accord "substantial consideration" to information from treating sources. Additionally, the court ordered reinstatement of benefits pending review for those claimants whose benefits were so terminated. 554 F.Supp. at 168-69; see also Mental Health Ass'n of Minn. v. Heckler, Supplemental Orders Feb. 11, 1983 and Mar. 31, 1983 (D.Minn). On appeal,5 the Secretary challenges the district court's jurisdiction as well as the propriety and scope of the relief awarded. We affirm the preliminary injunction issued by the district court with the modifications specified below.

The relevant statute establishes guidelines for disability determinations and delegates to the Secretary the duty to promulgate implementing regulations.6 Accordingly, the regulations provide a five-step sequential evaluation process, through which benefit claims are funneled. First, the Secretary determines whether an individual is engaged in "substantial gainful activity"; if so, benefits are denied. 20 C.F.R. Secs. 404.1520(b), 416.920(b) (1981). If not, the Secretary determines whether the claimant's medical condition or impairment is "severe"; if found "not severe," benefits are denied. Id. Secs. 404.1520(c), 404.1521, 416.920(c). Third, the Secretary determines whether the claimant suffers from an impairment acknowledged to be so severe that the claimant is presumed to be incapable of pursuing any gainful activity. If so, then the claimant meets or equals the Listing of Impairments and benefits are awarded. Id. Secs. 404.1520(d), 416.920(d); see "Listing of Impairments," supra. However, if the claimant's impairment does not satisfy the Listing of Impairments, the fourth step requires the Secretary to determine whether the individual has a sufficient "residual functional capacity" (RFC) to perform his former work. If so, benefits are denied. Id. Sec. 404.1520(e); see id. Sec. 404.1545(c). If an individual still has not been ruled ineligible for benefits, the fifth step requires the Secretary to take into account the additional considerations of age, education, and past work experience to determine whether the individual is capable of performing any other work available in the economy. Id. Sec. 404.1520(f)(1).

The primary issue before the district court concerned the RFC determination made in the fourth step. An individual's RFC is derived from a comprehensive, individualized assessment of the claimant's limitations--physical and mental. See id. Sec. 404.1545-.1569. On the basis of the RFC, the Secretary determines whether the individual retains the ability to perform his or her past work. The district court, however, found that in early 1980, the state DDS (Disability Determination Service) agents in Region V applied a different standard.7 The court found that the policy prevalent in Region V was for state DDS agents to apply a presumption that those claimants whose mental impairments were not as severe as those in the Listing of Impairments retained a sufficient RFC to do at least unskilled work. The effect of this presumption was that mentally impaired claimants ruled ineligible for benefits under the third step were presumed ineligible under the subsequent steps, thereby bypassing the individual assessment required in the fourth level. On the basis of this finding, the district court issued its preliminary injunction.

Jurisdiction

A threshold question is raised concerning the district court's jurisdiction. The complaint alleges jurisdiction under section 205(g) of the Social Security Act, 42 U.S.C. Sec. 405(g) (1976 & Supp. V 1981),8 the mandamus statute, 28 U.S.C. Sec. 1361 (1976),9 and the general federal question statute, 28 U.S.C. Sec. 1331 (1976 & Supp. V 1981).

The district court did not state its jurisdictional basis; however, the court apparently relied on Aldrich v. Schweiker, 555 F.Supp. 1080 (D.Vt.1982). In Aldrich, plaintiffs brought a class action alleging that the defendant's regulations, policies, and practices used in disability determinations did not comport with the Social Security Act.

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720 F.2d 965, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mental-health-association-of-minnesota-v-heckler-ca8-1983.