Astrue v. Capato Ex Rel. B. N. C.
132 S. Ct. 2021
| SCOTUS | 2012Background
- Karen Capato sought Social Security survivors benefits for twins conceived posthumously with her deceased husband’s frozen sperm; SSA denied.
- District Court applied intestacy-law criterion under §416(h)(2)(A) and Florida law, concluding posthumously conceived children could not inherit under intestacy.
- Third Circuit reversed, holding that under §416(e) the biological children of a deceased insured and his widow qualify for benefits without regard to state intestacy law.
- Supreme Court granted certiorari to resolve whether §416(e) or §416(h) governs, and how state intestacy law interacts with posthumous conception.
- Court ultimately held that SSA’s long-standing interpretation applying state intestacy law via §416(h)(2)(A) is reasonable and entitled to Chevron deference, reversing the Third Circuit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §416(h)(2)(A) govern child status for posthumously conceived children? | Capato argues §416(e) alone defines 'child'; posthumously conceived twins qualify as children of insured. | SSA treats §416(h) as the gateway; need to apply intestacy law to determine child status. | Yes; §416(h)(2)(A) governs. |
| Is the SSA's reading of §416(e) and §416(h) a permissible construction the Court should defer to under Chevron? | Capato contends the Third Circuit's view is correct and deference to agency isn’t warranted. | SSA's interpretation is reasonable and merits Chevron deference. | Yes; agency interpretation warrants Chevron deference. |
| Does applying state intestacy law to posthumously conceived children further the Act’s purpose to protect dependents? | Biological posthumous children should be treated as 'children' without rigidly applying intestacy rules. | Intestacy-law gateway aligns benefits with dependents likely to rely on support; minimizes administrative burden. | Yes; applying intestacy law serves the Act’s protective objective. |
Key Cases Cited
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837 (1984) (establishes deferential review for agency interpretations of statutes)
- Mathews v. Lucas, 427 U. S. 495 (1976) (dependence considerations and life-time support relevance to disability benefits)
- Weinberger v. Salfi, 422 U. S. 749 (1975) (time limits and duration-of-relationship considerations in social security)
- Califano v. Jobst, 434 U. S. 47 (1977) (purpose of providing protection to dependents of wage earners)
- United States v. Mead Corp., 533 U. S. 218 (2001) (guides when Chevron deference applies via delegation to agency)
- Beeler v. Astrue, 651 F.3d 954 (2011) (Ninth/8th Cir. agency interpretations of §416(h) and child status)
- Vernoff v. Astrue, 568 F.3d 1102 (2009) (arguments about rational-basis review for posthumously conceived children)
- Schafer v. Astrue, 641 F.3d 49 (2011) (posthumously conceived child's eligibility depends on intestacy law)
- Mathews v. Lucas, 427 U. S. 495 (1976) (dependency and protection rationale for social welfare statutes)