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Hagans v. Commissioner of Social Security

694 F.3d 287 (2012)

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Hagans v. Commissioner of Social Security

United States Court of Appeals for the Third Circuit

694 F.3d 287 (2012)

Facts

Mark Hagans (plaintiff) received disability benefits based on physical and emotional conditions. The Social Security Administration (SSA) (defendant) terminated Hagans’s disability benefits on September 1, 2004, after determining that his conditions had improved and finding that Hagans was now able to work. Hagans appealed and, in September 2008, had a hearing in front of an administrative-law judge (ALJ). In February 2009, the ALJ upheld the SSA’s decision. Hagans appealed to the district court, which reviewed Hagans’s disability status as of September 1, 2004. Hagans argued that according to § 423(f)(1) of the Social Security Act, the district court should have reviewed his disability status either at the time of his ALJ hearing or the ALJ decision. The SSA argued that the district court correctly reviewed Hagans’s disability status at the time the SSA terminated Hagans’s benefits. In its argument, the SSA pointed to an acquiescence ruling it issued in 1992 that interpreted § 423(f)(1) to require a benefits recipient’s disability status to be evaluated at the time the SSA first determined that the benefits should be terminated. The acquiescence ruling reflected the SSA’s internal policies but did not have the force of law. The district court affirmed the SSA’s initial termination decision, and Hagans appealed.

Rule of Law

Issue

Holding and Reasoning (Chagares, J.)

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