Pierce v. Commissioner

Lois Pierce (plaintiff) worked for the Social Security Administration (SSA) (defendant) until 1982, after which she took an unpaid leave of absence because of mental impairment. In May 1983, Pierce applied for the Civil Service Retirement System (CSRS) disability retirement pension. The Office of Personnel Management (OPM) denied Pierce’s application because of insufficient medical evidence. Pierce petitioned for reconsideration and submitted additional evidence demonstrating she suffered from a psychiatric disease that impaired her ability to perform her employment duties. OPM approved Pierce’s second application, finding that Pierce was eligible for disability pension benefits as of April 1984. In 2003, Pierce applied for social security spousal benefits. Although her application was initially approved, SSA subsequently notified Pierce that her benefits had been overpaid because SSA neglected to apply the pension offset to her spousal benefits. SSA informed Pierce that the pension offset reduced her spousal benefit to zero, eliminating Pierce’s spousal benefit eligibility. Pierce requested a hearing, arguing that (1) she was eligible for the CSRS pension prior to July 1983 even though OPM only approved her pension eligibility commencing April 1984; and (2) because she was eligible before July 1983, the pension offset did not apply. The administrative-law judge (ALJ) affirmed the denial, finding that Pierce had failed to prove she was eligible for her pension prior to July 1983. Pierce did not submit additional medical evidence at the hearing. The SSA Appeals Council affirmed the ALJ’s decision. Pierce appealed to federal district court.