Schweiker v. Chilicky

In the early 1980s, Congress enacted legislation requiring disability determinations made under the Social Security Act to be reviewed at least once every three years. These disability reviews were modeled on existing procedures for new claimants. Recipients had to show that their disability qualified for benefits under the act. A state agency performed the review guided by federal criteria. Adverse decisions could be appealed for de novo review by the same agency. A second appeal could be made to an administrative-law judge acting on behalf of the Secretary of Health and Human Services. The claimant would then be entitled to a hearing before the Appeals Council of the Social Security Administration. After exhausting this administrative-review process, a claimant could then seek judicial review. The act provided no private action for money damages against public officials responsible for violations of constitutional protections. After the continuing-disability review program was implemented, program data showed that state agencies often wrongly denied benefits, which then had to be reinstated by administrative-law judges. Claimants entirely reliant on disability benefits to support themselves and their families would be denied payments for several months. To prevent financial hardship to claimants, Congress enacted emergency legislation providing for continued benefits pending administrative appeals. James Chilicky (plaintiff) was informed that his heart condition did not qualify as a statutory disability while he was in the hospital recovering from open-heart surgery. Chilicky bypassed administrative review and reapplied for benefits a year and half after his benefits were terminated. Chilicky’s application was approved, and he was retroactively awarded a year of benefits. Chilicky’s request for the remaining six months of lost benefits remained pending. Chilicky sued the public official (defendant) heading the state agency that had wrongfully denied him benefits. Among other remedies, Chilicky requested money damages. The district court found for Chilicky, and the intermediate appellate court affirmed. The United States Supreme Court granted certiorari.