Wallace v. Bowen

John R. Wallace (plaintiff) suffered a heart attack while working as a steel worker. He suffered a stroke one month later, which may have caused loss of vision in his right eye. Wallace applied for disability insurance benefits and supplemental security income (SSI) based on his heart condition and vision impairments. His claims were denied. Wallace sought a hearing before an administrative law judge (ALJ). At Wallace’s hearing, Wallace testified and introduced medical reports from his doctors detailing his physical impairments. After the hearing, the ALJ sent Wallace’s medical records to two consultative physicians under contract with the Department of Health and Human Services (HHS) (defendant). Both physicians found that Wallace’s impairments did not meet the criteria set forth in the Social Security Act (Act). Relying on these observations from the consultative physicians, the ALJ concluded Wallace was not disabled for the purposes of the Act. Based on this conclusion, HHS then found that Wallace was not entitled to social security disability insurance benefits or to SSI. Wallace sought review of this decision. The district court upheld the decision and granted HHS’s request for summary judgment. Wallace appealed, arguing (1) that the ALJ’s reliance upon medical reports obtained after the hearing and without an opportunity for Wallace to cross-examine the reports’ authors denied him his statutory right to have a decision on his claim based on evidence adduced at the hearing and his constitutional right to due process; and (2) that the ALJ’s decision was not supported by substantial evidence.