New York v. Heckler

105 F.R.D. 118
CourtDistrict Court, S.D. New York
DecidedMarch 11, 1985
DocketNo. 83 Civ. 5903 (RLC)
StatusPublished
Cited by10 cases

This text of 105 F.R.D. 118 (New York v. Heckler) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
New York v. Heckler, 105 F.R.D. 118 (S.D.N.Y. 1985).

Opinion

OPINION

ROBERT L. CARTER, District Judge.

The present motion is for certification of a class action in a challenge to defendants’ alleged administrative policy of using per se rules to deny and terminate Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI) disability benefits to New York State residents who suffer disabling cardiovascular impairment and inability to work. The per se rules are allegedly used for determining (1) whether an individual’s heart impairment is sufficiently severe to meet or equal the Listing of Impairments for cardiovascular disease established by the Secretary and (2) whether an individual suffering from heart disease has the residual function capacity (RFC) to engage in substantial gainful activity. As such, plaintiffs maintain that the evaluations preclude an individualized assessment of relevant medical evidence or of RFC, in violation of the Social Security Act, its implementing regulations, and the due process clause of the Fifth Amendment. Plaintiffs also charge that, because many of the challenged rules and procedures were not published in the Federal Register, they violate the Federal Register [121]*121Act,1 FrepHnrn of Information Act,2 and Administrative Procedures Act.3

The named plaintiffs are twelve individuals who are ioined by the State and Citv of [122]*122New York, Suffolk County, and the State and Suffolk County Departments of Social Services. Plaintiffs seek certification of a class action consisting of:

All New York State residents with cardiovascular impairments whose applications or eligibility for SSDI or SSI disability benefits have been or will be denied or terminated by the application of per se denial rules on or after June 1, 1980.

In addition, plaintiffs seek an order certifying as a subclass all members of the plaintiff class:

Who have ischemic heart disease, hypertensive vascular disease, myocardiopa-thies, or rheumatic or syphilitic heart disease and whose disability benefits have been or will be denied or terminated based on the application of per se denial rules pertaining to treadmill exercise tests.4

Defendants challenge the court’s jurisdiction over the class on whose behalf plaintiffs seek to bring this action, arguing that 42 U.S.C. § 405(g)5 mandates standards of exhaustion and time limitations not met by the plaintiff class.

The § 405(g) requirement of a “final decision of the Secretary made after a hearing” has been held to consist of two elements, a non-waivable jurisdictional requirement that a claim for benefits has been presented to the Secretary (“presentment”) and a waivable requirement that the administrative remedies prescribed by the Secretary have been exhausted (“exhaustion”). Mathews v. Eldridge, 424 U.S. 319, 328-330, 96 S.Ct. 893, 899-900, 47 L.Ed.2d 18 (1976); Weinberger v. Salfi, 422 U.S. 749, 764-765, 95 S.Ct. 2457, 2466, 45 L.Ed.2d 522 (1975); City of New York v. Heckler, 742 F.2d 729 (2d Cir.1984).

As to the presentment requirement, the Second Circuit adheres to the view that a recipient subject to continuing eligibility review can not meet this requisite through inaction. However, the submission, prior to termination, of a completed Social Security questionnaire indicating in writing that the recipient remains disabled and desires continued benefits satisfies the presentment yardstick. City of New York v. Heckler, supra.

In the present case, all class members whose benefits were terminated either completed such a form or, as called for by the Social Security Administration’s Program Operations Manual System (POMS) §§ 00504 et seq., participated in its completion. Wheeler v. Heckler, 719 F.2d 595, 600 (2d Cir.1983). Further, the inclusion of class members who will be denied or terminated from benefits in the future presents no jurisdictional problem since such individuals will not actually be covered by any order or judgment entered in these cases until they make a claim for benefits in some form, thus satisfying the presentment requirement. Dixon v. Heck[123]*123ler, 589 F.Supp. 1494, 1512 (S.D.N.Y.1984) (Lasker, J.).

The need to exhaust administrative remedies may be waived by the court in appropriate circumstances. City of New York v. Heckler, supra, 742 F.2d at 736. This waiver may be exercised where plaintiffs’ legal claims are collateral to the demand for benefits, where exhaustion would be futile, or where the harm suffered pending exhaustion would be irreparable. Id. No one factor is critical and “a general approach, balancing the competing considerations to arrive at a just result under the circumstances presented” has been adopted by this circuit. Id.

As in City of New York, issues of collaterally and futility make waiver appropriate here.

[T]he class here complains fundamentally of a procedural irregularity and not of the Secretary’s substantive standards of eligibility. The District Court was not asked to and did not rule on the merits of any of the underlying claims. In this regard cases such as Heckler v. Lopez, [463 U.S. 1328, 104 S.Ct. 10, 77 L.Ed.2d 1431]; Heckler v. Ringer, [— U.S. -, 104 S.Ct. 2013, 80 L.Ed.2d 622 (1984)] and Smith v. Schweiker, [709 F.2d 777 (2d Cir.1983) ], which involved challenges to the Secretary’s substantive standards, are distinguishable. We conclude, therefore, that although not ‘wholly’ collateral, plaintiffs’ claims are substantially collateral to their entitlement to disability benefits and consequently present an appropriate circumstance for waiver. [Citations omitted].
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Moreover, under the. circumstances of this case, exhaustion of administrative remedies would have been futile____ [T]he administrative process can not vindicate the procedural rights asserted in this litigation. The class members complain of a procedural irregularity—the failure of the Secretary to base eligibility determinations on individualized assess-ments____ This procedural right, guaranteed by the Secretary’s regulations, cannot be vindicated by an ultimate determination of eligibility. For that reason further exhaustion may justifiably be waived.

Id. at 737.

A further obstacle to certification of the class is the sixty day limitation imposed by 42 U.S.C. § 405(g), supra at note 2. Under that statute, claimants must seek judicial review of final decisions of the Secretary “within sixty days after the mailing ...

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Bluebook (online)
105 F.R.D. 118, Counsel Stack Legal Research, https://law.counselstack.com/opinion/new-york-v-heckler-nysd-1985.