## Facts

- Fay Crane applied in 1989 for adult child’s insurance benefits on her father’s Social Security earnings record, alleging disability beginning before age 22.
- Crane had been continuously married since 1968 at the time she filed her application.
- Crane’s husband had been receiving Social Security disability benefits for several years before her application.
- The Social Security Administration denied the claim initially and on reconsideration.
- After a de novo hearing, an Administrative Law Judge denied benefits because Crane was married when she applied; the decision became the Secretary’s final decision.
- In federal court review under 42 U.S.C. § 405(g), the district court granted summary judgment to Crane and remanded for evaluation of her disability, reading 42 U.S.C. § 402(d)(5) as limiting the “unmarried” requirement for eligibility.

## Issues

1. Whether 42 U.S.C. § 402(d)(5) modifies § 402(d)(1)’s requirement that an applicant for adult child’s insurance benefits be unmarried at the time of application, allowing initial entitlement for a married applicant.
2. Whether the Secretary’s longstanding interpretation—treating § 402(d)(5) as preventing termination of benefits for certain existing beneficiaries, not creating entitlement for married first-time applicants—must be upheld.

## Decision

- The Eighth Circuit reversed the district court and upheld the Secretary’s denial of benefits.
- The court held that § 402(d)(1) requires an adult child’s benefits applicant to be unmarried when the application is filed and that marriage is a terminating event.
- The court held that § 402(d)(5) does not create initial entitlement for married applicants; it functions only to prevent termination for certain beneficiaries already receiving child’s benefits when they marry.
- Applying deference principles to the agency’s reasonable, longstanding construction, the court concluded the district court improperly substituted its own reading for the Secretary’s permissible interpretation.
- Because Crane was married at filing and had never previously received child’s benefits, she was statutorily ineligible and the case was not remanded for a disability determination.

## Legal Principles

- Initial entitlement to adult child’s insurance benefits under 42 U.S.C. § 402(d)(1) requires the applicant to be unmarried at the time the application is filed.
- Section 402(d)(5) is a non-termination provision that can preserve benefits for certain existing beneficiaries who marry; it does not override the unmarried-at-filing requirement or create eligibility for married first-time applicants.
- When statutory provisions are ambiguous, courts must defer to a reasonable, permissible, and longstanding agency interpretation and may not replace it with a judicial construction.

## Conclusion

The Eighth Circuit held that a claimant married at the time of applying for adult child’s insurance benefits is categorically barred by § 402(d)(1), and § 402(d)(5) does not supply initial entitlement because it only prevents termination for certain beneficiaries already receiving benefits at the time of marriage.


Crane v. Sullivan, 993 F.2d 1335 (8th Cir. 1993)