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In Re Margaret M. HECKLER, Secretary of the Department of Health and Human Services, Petitioner
Citations: 751 F.2d 954; 1984 U.S. App. LEXIS 15536; 8 Soc. Serv. Rev. 189Docket: 84-1803
Court: Court of Appeals for the Eighth Circuit; December 31, 1984; Federal Appellate Court
Margaret Heckler, Secretary of the Department of Health and Human Services, filed a petition for a writ of mandamus to vacate a June 11, 1984, order from Judge McManus, which required her personal appearance in court to show cause for potential civil contempt. This order stemmed from two cases where the Social Security Administration allegedly failed to comply with court directives regarding plaintiffs’ complaints of pain. The Appeals Council had remanded the cases to an administrative law judge (ALJ), instructing adherence to both the court's orders and relevant regulations pertaining to pain in disability evaluations. Following the contempt order, the Appeals Council awarded benefits to claimant Trickel on June 14, 1984, contradicting the ALJ's earlier recommendation for denial. On July 17, 1984, the Eighth Circuit recognized a settlement agreement in a related class action, Polaski v. Heckler, which clarified the law on evaluating pain and subjective complaints for disability determinations. The Social Security Disability Benefits Reform Act of 1984, signed on October 9, 1984, further established standards in this area. Given the developments in the Polaski case and the enactment of the 1984 Act, the appellate court found that the issues regarding the Secretary's actions had been resolved. Therefore, a finding of contempt was deemed inappropriate. The court expected the district court to vacate its June 11 order but noted that if it failed to do so, the Secretary could renew her petition for expeditious handling. The petition for the writ was denied and the case was remanded to the district court. The ALJ is instructed to adhere to the procedures outlined in the Court's remand order while being reminded that under Social Security Administration Regulations 404.1529 and Ruling 82-58, pain is classified as a symptom rather than an impairment. Although symptoms like pain are critical in assessing disability, the Social Security Act mandates that an individual's self-reported symptoms must be evaluated alongside relevant medical signs and laboratory results. Regulations 404.1528, 404.1529, 416.928, and 416.929 clarify that personal statements alone cannot substantiate a severe mental or physical impairment. A determination of 'disabled' necessitates medical evidence indicating a severe condition that could reasonably account for the claimed symptoms. Additionally, Frank V. Smith III, Associate Commissioner for Hearings and Appeals, noted in an affidavit that the SSA is willing to restore Trickel's benefits from January 1983 to June 1984 upon request. The Appeals Council previously rejected the ALJ's unfavorable recommendation regarding Trickel and mandated a review consistent with Eighth Circuit law, occurring after the claimants' motion for an order to show cause.