## Facts

- Title II of the Social Security Act provides disability insurance benefits and establishes a multi-step administrative review process, including reconsideration and an evidentiary hearing before an Administrative Law Judge (ALJ).
- A statewide class of Vermont disability claimants sued the Secretary of Health and Human Services, alleging excessive delays at the reconsideration and ALJ-hearing stages.
- Claimants argued the delays violated 42 U.S.C. § 405(b), which requires the agency to provide a hearing “within a reasonable time.”
- The district court found delays exceeding 90 days at reconsideration and at the hearing-request stage unreasonable.
- The district court issued a statewide injunction requiring:
  - reconsideration determinations within 90 days of a request;
  - ALJ hearings within 90 days of a hearing request; and
  - interim benefits if adjudication did not occur within specified periods tied to these deadlines.
- The Second Circuit affirmed the injunction.

## Issues

1. Whether § 405(b)’s “reasonable time” requirement permits a federal court to impose fixed, across-the-board deadlines for adjudicating all future Title II disputed disability claims.
2. Whether a court may order payment of interim benefits triggered by the agency’s failure to meet such judicially imposed deadlines.

## Decision

- The Supreme Court vacated the Second Circuit’s judgment and remanded.
- The Court held the injunction invalid because it imposed systemwide deadlines and interim-benefit requirements not authorized by the Act.
- The Court concluded the injunction was an unwarranted judicial intrusion into a pervasively regulated area of federal benefits administration.
- The Court emphasized that Congress had repeatedly considered and rejected mandatory adjudication deadlines, favoring a balance between timeliness and accuracy given workload and resource constraints.

## Legal Principles

- Section 405(b)’s requirement of a hearing “within a reasonable time” does not authorize courts to impose uniform, systemwide processing deadlines for Social Security disability claims.
- When Congress has specifically addressed an administrative timing problem and declined to adopt mandatory deadlines, courts generally may not create deadline regimes through equitable relief.
- Structural, forward-looking injunctions that reallocate agency priorities and compel broad administrative reorganization exceed proper judicial remedial authority in a detailed statutory and regulatory scheme.
- Court-ordered interim benefits tied to noncompliance with judicially created deadlines improperly alter the statutory design governing when benefits are payable.

## Conclusion

The Supreme Court invalidated a statewide injunction that required the Social Security Administration to meet fixed adjudication deadlines and pay interim benefits for missed deadlines, holding that § 405(b) does not permit courts to impose systemwide timing and payment rules that Congress repeatedly declined to enact.


Heckler v. Day, 467 U.S. 104 (1984)