Coulston v. Apfel

Jim Coulston (plaintiff) was receiving Social Security benefits due to a severe mental impairment. The administration overpaid Coulston by sending him a check in excess of $20,000. Coulston, with the help of his ex-wife and a friend, cashed the check and spent all but a little over $2,000 on bills and Christmas presents. Coulston had been overpaid by the administration 15 years prior, but there is no mention in the record that Coulston recalled that overpayment. Further, Coulston believed that he was entitled to the overpayment because he had received letters from the administration indicating an increase in his benefits payments and suspected the overpayment was for medical bills he incurred after letting his Medicare lapse. Coulston returned the unspent portion of the overpayment; however, the administration sought to recover that which Coulston had already spent. Coulston sought a waiver from repayment, but following an administrative-law judge (ALJ) hearing, Coulston was ordered to return the unspent money immediately, despite the ALJ’s acknowledgement of Coulston’s intellectual limitations. The ALJ based the decision on the intellectual capacity of Coulston’s ex-wife and friend who helped him cash and spend the overpayment. Coulston sought judicial review of the ALJ’s determination, which became the final decision of the Commissioner of the Social Security Administration, Kenneth Apfel (defendant). The ALJ’s decision was affirmed, and Coulston appealed.