## Facts

- Lucille Smith applied for Social Security widow’s insurance benefits as the widow of deceased wage earner Yarbrough Smith.
- In 1938, Smith began a relationship with Darryl Knight in Alabama; five children were born during the relationship, and no marriage ceremony occurred.
- Smith and Knight separated in the mid-1940s and never formally dissolved any alleged marital relationship.
- In 1949, Smith began cohabiting with Yarbrough Smith in Florida; she used the surname “Smith,” and the community regarded them as husband and wife.
- Smith and Yarbrough had a child, filed joint income tax returns, purchased insurance, and conducted business as a married couple; in 1968 Yarbrough listed Smith as his wife on a retirement-benefits application.
- Yarbrough died in 1975; Smith applied for widow’s benefits in 1979.
- An ALJ denied benefits, finding Smith’s Florida common-law marriage to Yarbrough invalid because Smith allegedly had a prior undissolved common-law marriage to Knight under Alabama law.
- The district court affirmed the Secretary’s denial; Smith appealed.

## Issues

1. Whether the agency and district court applied the correct legal standard when determining Smith’s marital status for widow’s benefits, including whether her earlier Alabama relationship constituted a valid, undissolved common-law marriage that barred recognition of a later marriage.
2. Whether the substantial-evidence standard insulated the denial when the asserted error concerned the legal standards governing marital status rather than factfinding.

## Decision

- The Eleventh Circuit reversed the district court’s judgment affirming the denial of benefits.
- The court held that the Secretary and the district court applied an incorrect legal standard in evaluating Smith’s marital status under applicable state law.
- The case was remanded for further proceedings applying the correct legal standard.

## Legal Principles

- Judicial review under 42 U.S.C. § 405(g) is deferential as to factfinding: courts may not reweigh evidence or substitute their judgment for the agency’s factual determinations if supported by substantial evidence.
- No similar deference applies to the agency’s conclusions of law, including identification and application of the proper legal standards.
- Failure to apply the correct legal standard in Social Security adjudication is reversible error.
- Eligibility for widow’s insurance benefits under 42 U.S.C. § 402(e)(1) depends on a legally valid widow status, which requires correct application of the relevant state-law rules governing marriage (including any asserted common-law marriage) and any impediments based on a prior undissolved marriage.

## Conclusion

The Eleventh Circuit required reversal because the denial of widow’s benefits rested on misapplication of the governing legal standards for determining marital status under state law, a legal error not protected by substantial-evidence deference.


Smith v. Heckler, 707 F.2d 1284 (11th Cir. 1983)