Heckler v. Day

Title II of the Social Security Act provided disability insurance benefits to claimants who could not pursue gainful employment due to their disabilities. The Act set forth a four-step process for the review and adjudication of disputed claims. First, state agencies determined whether the claimant had a disability and when the disability began or ended. Second, a claimant could request reconsideration of an adverse determination. Third, a claimant who received an adverse decision could seek an evidentiary hearing. Fourth, a claimant who received an adverse decision after a hearing could appeal to the Appeals Council of the Department of Health and Human Services (defendant). Leon Day (plaintiff) brought a class action lawsuit seeking declaratory and injunctive relief from delays in steps two and three of the review and adjudication process. Day waited 167 days to receive a reconsideration determination and 173 days to receive a hearing after his request. The district court determined that delays of longer than ninety days at the reconsideration and hearing stages were unreasonable and violated the claimants’ statutory rights. The district court issued an injunction directing the Secretary of the Department to issue reconsideration determinations and provide hearings within ninety days. The Court of Appeals for the Second Circuit affirmed. The Department appealed, arguing that the injunction was contrary to congressional intent and was an abuse of the court’s equitable power.