## Facts

- The Social Security Act defines “disability” as an inability to engage in substantial gainful activity due to a medically determinable impairment that has lasted or can be expected to last for at least 12 continuous months.
- Cleveland B. Walton had a mental impairment that prevented him from working, but he returned to substantial gainful activity after 11 months.
- Applying its regulations and interpretive guidance, the Social Security Administration (SSA) denied Walton’s Title II and Title XVI disability claims because his inability to work did not last, and could not be expected to last, 12 months.
- A federal district court affirmed the denial.
- The Fourth Circuit reversed, reasoning that the 12-month duration requirement modifies the “impairment,” not the “inability,” and that SSA could not treat Walton’s actual return to work within 12 months as controlling on the “expected to last” determination.
- The Supreme Court granted certiorari to review the validity of SSA’s interpretations.

## Issues

1. Whether the Social Security Act unambiguously bars SSA from requiring that the claimant’s inability to engage in substantial gainful activity last (or be expected to last) at least 12 months.
2. Whether SSA may treat a claimant’s actual return to substantial gainful activity within 12 months, before the agency decision, as decisive evidence that the inability was not “expected to last” 12 months.

## Decision

- The Supreme Court reversed the Fourth Circuit and upheld SSA’s denial of benefits.
- The Court held the statute does not unambiguously forbid SSA’s requirement that the inability to engage in substantial gainful activity satisfy the same 12-month duration requirement as the impairment.
- The Court held SSA may treat an actual return to substantial gainful activity within 12 months, before adjudication, as showing the inability was not “expected to last” 12 months.
- The Court applied Chevron and concluded SSA’s interpretations were within its lawful interpretive authority; it also gave weight to deference owed to the agency’s interpretation of its own regulations.

## Legal Principles

- When a statute is silent on a precise question, that silence generally creates ambiguity rather than resolving the issue, permitting deference to a reasonable agency construction.
- Under Chevron, courts ask (1) whether Congress has directly addressed the precise question and, if not, (2) whether the agency’s interpretation is reasonable.
- SSA may reasonably interpret “disability” as a unitary concept requiring that both the medically determinable impairment and the resulting inability to engage in substantial gainful activity last (or be expected to last) at least 12 months.
- SSA may reasonably use the claimant’s actual return to substantial gainful activity within 12 months, before the agency decision, to determine that the inability was not expected to last the required duration.
- Courts may give significant weight to a longstanding agency interpretation, and deference may apply even when an interpretation was not first announced through notice-and-comment rulemaking.

## Conclusion

The Court sustained SSA’s regulations and interpretations requiring a 12-month duration for the inability to work and permitting SSA to treat a claimant’s return to substantial gainful activity within 12 months as defeating the “expected to last” requirement, reversing the Fourth Circuit and affirming denial of benefits to Walton.


Barnhart v. Walton, 535 U.S. 212 (2002)