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Crane v. Sullivan

993 F.2d 1335 (1993)

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Crane v. Sullivan

United States Court of Appeals for the Eighth Circuit

993 F.2d 1335 (1993)

Facts

Fay Crane (plaintiff) filed for adult child’s insurance benefits at the age of 45, alleging several physical and emotional limitations because of her disability stemming from her glaucoma, depression, and low I.Q. Crane claimed entitlement to the benefits because her father was a fully insured recipient of Social Security retirement benefits. When she filed her application, Crane was married to an individual who was receiving Social Security disability benefits. The Secretary of Health and Human Services, Louis Sullivan (defendant), denied Crane’s application because she was married in contravention of 42 U.S.C. § 402(d)(1)’s prohibition against married applicants. Further, in accordance with his long-standing interpretation, the secretary concluded that § 402(d)(5) did not operate to create an entitlement to benefits for applicants who were married prior to their applications for child’s insurance benefits. Crane sued the secretary in a United States district court to overcome the denial. The district court gave no deference to the secretary’s interpretation of § 402(d)(5), reversing his decision and holding that Crane would be eligible for benefits if she proves her disability because § 402(d)(5) limits the prohibition against married applicants. The secretary appealed.

Rule of Law

Issue

Holding and Reasoning (Peck, J.)

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