Tackett v. Apfel

Richard Tackett (plaintiff) had knee problems. In September 1991, Tackett fell while at work and thereafter was unable to continue working as a machinist. In 1994, Tackett took a job in a hardware store but had to quit a month later because of his knees. Tackett applied for Social Security disability benefits, asserting that he had been disabled since September 1991. The commissioner of the United States Social Security Administration, Kenneth Apfel (commissioner) (defendant), denied Tackett’s application. Tackett then requested a hearing before an administrative-law judge (ALJ). Tackett’s physicians and the ALJ’s medical experts agreed that Tackett could perform some sedentary work but needed to be able to change positions and walk every half hour. The ALJ determined that Tackett became disabled when he turned 50 on February 7, 1995, but was not disabled before that, finding that Tackett could have worked eight-hour shifts with breaks every two hours. The ALJ did not call a vocational expert to testify at Tackett’s hearing and based his determination solely on the Medical-Vocational Guidelines, commonly known as the grids. The grids used several factors, including age, education, and work experience, to assess a claimant’s ability to find work. An appeals council declined Tackett’s request for review, and Tackett appealed to the district court, which affirmed the ALJ’s decision. Tackett appealed again, arguing that he was entitled to benefits for the period between September 1991 and his fiftieth birthday.