Social Security Act

Astrue v. Capato

Issues

Is a child conceived after the death of a biological parent eligible to receive survivor benefits under the Social Security Act regardless of state intestacy laws?

 

Shortly after Robert Nicholas Capato’s death, his wife Karen Capato underwent in vitro fertilization using his frozen sperm and gave birth to twins in 2003. Karen Capato applied for Social Security benefits on behalf of her twins as survivors of a deceased wage earner. The Social Security Administration ("SSA") denied her claim. An Administrative Law Judge (“ALJ”) affirmed, ruling that state intestacy law controls eligibility for survivor benefits for posthumously conceived children under the Social Security Act ("Act"). Therefore, the twins were ineligible for benefits under the applicable Florida law. On appeal, the district court affirmed the ALJ’s reading. The United States Court of Appeals for the Third Circuit reversed and ruled that the plain language of the Act entitles the Capato twins, whose parentage is not in dispute, to survivor benefits. Petitioner Michael J. Astrue, Commissioner of the SSA, argues that the Act requires the agency to apply state intestacy law to determine whether an applicant is the child of an insured wage earner for the purpose of receiving survivor benefits. In contrast, Respondent Karen K. Capato contends that the Act unambiguously entitles undisputed biological children of married parents to survivor benefits, without referring to state intestacy laws. The Supreme Court’s decision will authoritatively interpret the Act’s mandate on the determination of survivor benefits eligibility, and possibly reflect on the balance between legislative rulemaking and unanticipated progress of science and technology.

Questions as Framed for the Court by the Parties

Whether a child who was conceived after the death of a biological parent, but who cannot inherit personal property from that biological parent under applicable state intestacy law, is eligible for child survivor benefits under Title II of the Social Security Act, 42 U.S.C. 401 et seq.

Shortly after Karen and Robert Nicholas (“Nick”) Capato were married in New Jersey in 1999, Nick Capato was diagnosed with cancer. See Capato v. Comm’r of Soc. Sec., 631 F.3d 626, 627 (3rd Cir.

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Carr v. Saul

Issues

Must claimants seeking Social Security benefits administratively exhaust their constitutional claims before seeking judicial review?

This case asks the Supreme Court to determine whether Social Security claimants must exhaust constitutional legal issues before an intra-agency adjudicative body—such as a Social Security Administration administrative law judge or appeals board—before seeking review of that issue in court. Petitioner Willie Carr argues that a requirement of issue exhaustion is inappropriate for his Appointments Clause challenge because no statute mandates issue exhaustion and a judicially-crafted requirement would break with historical precedent. Respondent Andrew Saul, Commissioner of the Social Security Administration, counters that a general rule of judicial economy is applicable here, and that all issues can and must be exhausted before an administrative body before a claimant can seek review. This case has important implications for the procedural ease of new challenges to prior adverse benefits rulings for Social Security claimants, as well as the dockets of reviewing courts.

Questions as Framed for the Court by the Parties

Whether a claimant seeking disability benefits under the Social Security Act forfeits an appointments-clause challenge to the appointment of an administrative law judge by failing to present that challenge during administrative proceedings.

In 2014, Willie Earl Carr attempted to claim disability benefits from the Social Security Administration (“SSA”). Carr v. Comm’r, SSA at 5. In 2017, administrative law judges (“ALJs”) denied the claims. Id. Carr then sued in the Northern District of Oklahoma.

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Lockhart v. United States

Issues

The Supreme Court faces an issue of statutory construction and interpretation in this case. The language in the Debt Collection Improvement Act (as of 1982) conflicts with language in the Higher Education Assistance Act (as of 1991) as to the time limitation on collection of debt owed to the government. The former prohibits collection of debt more than 10 years outstanding, while the latter contains a clause explicitly stating that there is no such limitation. The Court will hold that either the earlier statute is controlling because it has not been explicitly repealed (thus, shielding debt more than 10 years outstanding), or else the later statute's language constructively repeals the earlier provision (thus, making all debt to the government susceptible for collection).

 

The language of the Higher Education Assistance Act clearly countermands any statute of limitations found in other statutes or administrative law that may bar the government from collecting, through administrative asset or garnishment, outstanding student loan debt. However, the amended Debt Collection Act, the Debt Collection Improvement Act, which was passed after the Higher Education Assistance Act, included language that expressly prevented administrative offset of social security benefits if the claim was outstanding for more than ten years. The Eighth and Ninth Circuits disagree as to whether the ten year statute of limitations applies to prevent offset of social security benefits. If Congress intended to protect social security benefits from administrative offset, then seriously delinquent debtors will be excused from repayment in this fashion. However, should the Court decide that Congress intended to prospectively abrogate the statute of limitations when it passed the Higher Education Assistance Act, then the government will be able to collect overdue student loans by withholding a certain amount from the debtor's social security benefits. Either way, statutory safeguards exist to protect those beneficiaries whose sole income is social security from offsets of excessive amounts.

Questions as Framed for the Court by the Parties

Do the Social Security Act and the Debt Collection Improvement Act bar the United States from withholding social security benefits to collect student loan debt that has been outstanding for more than ten years, as the Eighth Circuit has held, or does the Higher Education Act eliminate any such bar, as the Ninth Circuit held below?

A. Statutory Background

The Debt Collection Act of 1982 (31 U.S.C ? 3716) provided for the collection of outstanding debts owed to the United States through means of administrative offset.? Under this statute, the United States could apply to an administrative agency in order to recoup debt owed by an individual.

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