Grunfeder v. Heckler

Felicia Grunfeder (plaintiff) was smuggled out of the Warsaw ghetto as a young child by being placed in a coffin and lifted over the fence that separated the Jewish and Polish cemeteries. Grunfeder lived with a family in the Polish section of Warsaw until the family was sent to a concentration camp. At the end of the war, Grunfeder and her mother were reunited and moved to the United States. Grunfeder’s father and other family members were killed by the Nazis. In response to demands for reparations after the war, the Federal Republic of Germany adopted legislation that provided for restitution for lost property, possessions, and economic advancement and for injury to body and health. As a result of her wartime experiences, Grunfeder developed disabling psychological problems and petitioned for and received monthly reparations payments from the German government. Grunfeder also applied for and received supplemental-security-income (SSI) benefits. The United States Social Security Administration (SSA) determined that the reparations payments were unearned income that made Grunfeder ineligible for SSI benefits and terminated Grunfeder’s benefits. Margaret Heckler (defendant), as secretary of the United States Department of Health and Human Services, denied Grunfeder’s motion for reconsideration. Grunfeder’s appeal was denied, as was her request for a review of the administrative-law judge’s denial of her appeal. Grunfeder filed an action against Heckler seeking review of the administrative-law judge’s decision. The district court dismissed the complaint. Grunfeder appealed.