Smith v. Shalala
United States District Court for the District of New Jersey
910 F. Supp. 152 (1995)
- Written by Nicole Gray , JD
Facts
Mary Smith (plaintiff) applied for and was denied disability insurance benefits because she had not reported enough earned income to be fully insured under the Social Security Act. Smith first learned that she did not meet the insured-status requirements when the Secretary of Health and Human Services, Donna Shalala (defendant), rejected Smith’s application. Smith sought to amend her 1983 and 1984 tax returns, which she filed jointly with her husband, to reflect her self-employment income for those years. Smith had not been able to report the income originally and had been forced to sign the joint returns as filed because she was allegedly under duress. Smith’s husband was physically and emotionally abusive and did not allow Smith to even review the original returns before she signed them. Smith filed suit in a United States district court, conceding that her amended tax returns were filed following the statute of limitations set forth in the Social Security Act. However, Smith requested that the court use its equitable powers to toll the statute of limitations and to direct the secretary to accept the untimely submitted amended tax returns as proof of Smith’s income.
Rule of Law
Issue
Holding and Reasoning (Lechner, J.)
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