Barry v. Heckler

Margaret Heckler, the secretary of health and human services (the secretary) (defendant), created the Bellmon Review Program (the program) to review the decisions of administrative-law judges. The program allowed the Office of Hearings and Appeals to target administrative-law judges with high rates of approving disability applications. If an administrative-law judge was targeted for review, the Appeals Council (the council) could review all of his decisions on its own motion. Targeted administrative-law judges could also be forced to attend counseling sessions and, if their high rates of approval continued, were threatened with further actions. George L. Barry (plaintiff), a carpenter, had a heart attack that prevented him from working. In 1982 Barry applied for disability benefits. The administrative-law judge determined that Barry was only able to perform sedentary work and granted Barry disability benefits. As part of the program, the council reviewed the administrative-law judge’s decision and reversed his grant of disability benefits, finding that Barry was able to perform medium-activity work. Barry filed a lawsuit in federal district court against the secretary, claiming that the program violated the Due Process Clause of the Fifth Amendment by incentivizing administrative-law judges to deny applications for disability benefits or face consequences from the council. Barry and the secretary filed motions for summary judgment. In support of her motion, the secretary argued that Barry did not have standing to bring the lawsuit, because the administrative-law judge, rather than Barry, was the party harmed by the council’s reversal. The secretary also argued that Barry’s due-process challenge was unwarranted because the council’s decision was supported by evidence.