## Facts

- A certified class of Social Security disability and SSI claimants challenged adverse decisions issued or handled by ALJ Russell Rowell in specified hearing offices and time periods.
- The class alleged Rowell harbored categorical bias against groups of claimants and used derogatory and stereotyped characterizations, leading to systematic unfair denials.
- Coworkers provided deposition testimony describing Rowell’s alleged hostile remarks, including racial slurs and assertions that certain claimants were “manipulative” or “malingering.”
- The SSA convened internal review panels that examined Rowell’s adjudications and twice concluded there was insufficient evidence of “general bias,” discounting coworker testimony as uncorroborated “opinion evidence,” particularly after Rowell’s death.
- On remand, plaintiffs developed additional evidence, including statistical analysis indicating an unusually high share of denials relied on improper credibility rationales (reported in summaries as approximately 84% in a defined subset).
- The case returned to the district court for review of whether the administrative handling of the bias allegations satisfied due process and whether the SSA’s internal findings could stand.

## Issues

1. Whether class members were denied due process because they did not receive a full and fair disability hearing before an impartial ALJ due to alleged general bias.
2. Whether the SSA’s internal panel determinations rejecting general bias were supported by substantial evidence and consistent with due process in light of the record as a whole.

## Decision

- The district court held that class members did not receive full and fair hearings before Rowell.
- The court rejected the SSA’s internal determinations that there was no general bias as inadequately supported when the full record was considered.
- The court relied on the combined force of coworker testimony and statistical evidence as showing a pattern consistent with categorical bias affecting adjudication.
- The court concluded that discounting eyewitness coworker accounts solely as “opinion” and requiring direct proof of state of mind was improper in evaluating systemic adjudicator bias.
- The court ordered relief aimed at providing claimants new consideration of their claims through unbiased adjudication procedures, including new hearings before different ALJs.

## Legal Principles

- Due process in Social Security adjudication requires a full and fair hearing before an impartial decision maker.
- “General bias” may be proven through cumulative evidence, including testimony from observers of adjudicator conduct and statistical patterns in decision-making.
- An agency’s internal review cannot satisfy due process if it dismisses probative evidence on an unduly narrow theory of proof and fails to account for the record as a whole.
- Where adjudicator bias taints a class of administrative decisions, an appropriate remedy includes new hearings or re-adjudication before a different, unbiased adjudicator.

## Conclusion

The court found that substantial testimonial and statistical evidence demonstrated that the class was denied impartial adjudication, rejected the SSA panels’ no-bias conclusions as unsound on the full record, and required remedial measures centered on new, unbiased consideration of affected claims.


Grant v. Comm’r of Soc. Sec. Admin., 111 F. Supp. 2d 556 (M.D. Pa. 2000)