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Sheryl Smith Schoenfeld, for Herself and on Behalf of Charles Mandeville, Kathleen Mandeville, and Jocelyn Mandeville v. Kenneth S. Apfel, Commissioner of Social Security

Citations: 237 F.3d 788; 2001 U.S. App. LEXIS 373Docket: 00-2261

Court: Court of Appeals for the Seventh Circuit; January 10, 2001; Federal Appellate Court

Narrative Opinion Summary

This case involves a legal dispute over the entitlement of children to Social Security benefits following the death of their presumed father, a college professor. After the father's death, his widow sought child benefits for her three children, as well as mother's benefits and a lump sum death benefit. Initially, an administrative hearing ruled in favor of the children, relying on the presumption of paternity under Wisconsin law. However, this decision was reversed by the Appeals Council, which found insufficient evidence to support the claim that the deceased was the natural father of the children. The U.S. District Court for the Western District of Wisconsin affirmed the Appeals Council's decision, granting summary judgment to the Commissioner of Social Security. The court held that substantial evidence supported the findings, including admissions regarding artificial insemination and legal documents refuting paternity. The appellate court upheld the district court's ruling, agreeing that the Appeals Council did not commit legal error. The case highlights issues of paternity presumption, the role of substantial evidence, and procedural considerations in administrative hearings. The appellant's constitutional claims were deemed waived, and arguments regarding the necessity of a guardian ad litem were dismissed, reinforcing the decision that the children did not qualify for benefits under the Social Security Act.

Legal Issues Addressed

Application of Substantial Evidence Standard

Application: The court evaluated whether the Appeals Council's findings were supported by substantial evidence, as required for upholding administrative decisions.

Reasoning: The appellate court affirmed the district court's decision, concluding that the Appeals Council's findings were supported by substantial evidence and did not involve legal error.

Presumption of Paternity under Wisconsin Law

Application: The case explores the presumption of paternity for children conceived during a marriage and the sufficiency of evidence required to rebut this presumption.

Reasoning: Charles Mandeville was conceived and born during the marriage of Clay and Sheryl, making the presumption that he is Clay's natural child applicable under section 891.39(1)(a).

Procedural Waiver of Constitutional Arguments

Application: The appellant's equal protection and due process arguments were waived on appeal for not being raised at the district court level.

Reasoning: Appellant's brief primarily raises equal protection and due process arguments under the Fifth Amendment, which were not presented to the district court and thus deemed waived on appeal.

Rebuttal of Paternity Presumption

Application: The court considered the evidence presented, including the lack of biological connection and statements from the parties, to rebut the presumption that the deceased was the father of the children.

Reasoning: The Appeals Council found sufficient evidence to rebut this presumption, citing several factors: Sheryl's admission that Charles was conceived through artificial insemination with Mandeville's sperm; a statement in the Judgment of Legal Separation indicating Charles was not Clay's child.

Requirements for Child's Insurance Benefits under Social Security Act

Application: The case discusses the criteria under the Social Security Act for a child to qualify as a beneficiary, focusing on marital status and paternity acknowledgment.

Reasoning: The definition of a 'child' under the Social Security Act encompasses natural children, legally adopted children, and, under certain conditions, stepchildren, grandchildren, step-grandchildren, and equitably adopted children.

Role of Guardian ad Litem in Paternity Cases

Application: Examines whether a guardian ad litem is necessary when challenging paternity presumptions under Wisconsin law and in administrative hearings.

Reasoning: The appellant argues that the Appeals Council erred by not appointing a guardian ad litem to represent the children's interests, as required by Wis. Stat. sec. 891.39 when challenging paternity presumptions.