Barnhart v. Walton

The Social Security Act authorizes payment of Title II disability insurance benefits and Title XVI Supplemental Security Income to individuals who have an “inability to engage in any substantial gainful activity by reason of any medically determinable … impairment … which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U. S. C. §423(d)(1)(A) (emphasis added); accord, § 1382c(a)(3)(A). The Social Security Administration (Agency) denied benefits to respondent Walton, finding that his “inability” to engage in substantial gainful activity lasted only 11 months. The District Court affirmed, but the Fourth Circuit reversed, holding that the 12-month duration requirement modifies “impairment” not “inability,” that the statute leaves no doubt that no similar duration requirement relates to an “inability,” and that therefore Walton was entitled to benefits despite Agency regulations restricting them to those unable to work for 12 months. The court decided further that Walton qualified for benefits because, prior to his return to work, his “inability” would have been “expected” to last 12 months. It conceded that the Agency had made Walton’s actual return to work within 12 months of his onset date and before the Agency’s decision date determinative on this point, 20 CFR §§ 404. 1520(b), 1592(d)(2), but found that the regulations conflicted with the statute.