## Facts

- Mabel Hansen sought Social Security “mother’s insurance benefits” and visited an SSA office in 1974 to ask if she qualified.
- An SSA field representative incorrectly told Hansen she was not eligible and did not suggest she file a written application.
- A regulation implementing § 202(g)(1)(D) required that applications for these benefits be filed in writing; absent a written application, no entitlement existed for the earlier period.
- Internal SSA Claims Manual instructions directed employees to suggest filing and explain the advantages of doing so, but the employee did not follow those instructions.
- In 1975, Hansen learned she was eligible, filed a written application, and began receiving benefits prospectively.
- Hansen sought retroactive benefits for the period she was eligible but had not filed a written application.
- The agency denied retroactive benefits; the district court and the Second Circuit held the government equitably estopped from denying retroactive benefits.
- The Supreme Court reversed.

## Issues

1. Whether the Secretary may be equitably estopped from enforcing the written-application requirement for retroactive Social Security benefits when an SSA employee gave erroneous advice and failed to follow internal manual instructions.
2. Whether an internal agency Claims Manual can bind the agency or create enforceable entitlement to benefits inconsistent with statute or regulation.

## Decision

- The Supreme Court reversed the Second Circuit in a per curiam decision.
- The Court held the Secretary was not equitably estopped from denying retroactive benefits for the period before a written application was filed.
- The Court held the SSA Claims Manual lacked the force of law and did not bind the agency like a duly promulgated regulation.
- The Court refused to excuse noncompliance with the written-application requirement based on equitable considerations or a “substantive eligibility” versus “procedural requirement” distinction.

## Legal Principles

- Courts must enforce statutory and regulatory conditions Congress (and valid regulations) impose on payment of federal funds; equitable remedies cannot override those conditions.
- Erroneous advice by a government employee, without “affirmative misconduct,” is insufficient to estop the government from applying valid eligibility requirements.
- Internal agency manuals and employee handbooks generally do not have the force of law and do not create enforceable rights to benefits contrary to governing statutes or regulations.
- A written application requirement for benefits operates as a condition of entitlement; courts may not disregard it to award retroactive payments.

## Conclusion

The Court held that a claimant cannot obtain retroactive Social Security benefits without satisfying a valid written-application requirement, even when an SSA employee provided incorrect advice and failed to follow internal manual guidance, because the manual is nonbinding and the government was not estopped on these facts.


Schweiker v. Hansen, 450 U.S. 785 (1981)