Stieberger v. Heckler

Theresa Stieberger and the City of New York (plaintiffs) sued the Secretary of Health and Human Services, Margaret Heckler (defendant), challenging the Social Security Administration’s nonacquiescence policy whereby the administration either ignored or issued explicit nonacquiescence rulings directing administrative-law judges (ALJ) to disregard court of appeals’ decisions that the administration disagreed with. In nonacquiescence cases, the administration refused to adhere to decisions of federal courts, even those in the circuits in which ALJs sat, except in the specific cases in which the decisions were rendered. The Second Circuit had a well-established rule that claimants’ treating physicians’ opinions of whether claimants were disabled were binding on the administration unless contradicted by substantial evidence. The physicians’ opinions did not need to be supported by objective clinical and laboratory findings for the circuit’s rule to take effect. The secretary’s policy regarding treating physicians was to give their opinions greater weight than nontreating physicians; however, their opinions could be rejected if unsupported by clinical or laboratory findings even without contradictory evidence in the administrative record. Further, the secretary had adopted the Seventh Circuit presumption that treating physicians’ opinions were not entitled to controlling weight because treating physicians may go to great lengths to prove disability of claimants with whom they have developed close relationships. Stieberger and the city argued that the secretary’s policies combined with the volume of overturned denials due to the administration’s failure to apply the circuit’s precedent proved the administration’s nonacquiescence to the governing legal standard. The administration’s policy allegedly deprived benefits claimants of impartial ALJs and unlawfully discriminated against claimants who lacked the resources to seek judicial review.