Beeler v. Astrue
2011 U.S. App. LEXIS 17983
| 8th Cir. | 2011Background
- Bruce Beeler died in 2001, domiciled in Iowa, after banking semen for Patti Beeler for posthumous conception.
- Patti Beeler conceived B.E.B. via intrauterine insemination with Bruce's frozen semen; B.E.B. was born in 2003 and Bruce is her biological father.
- SSA denied B.E.B.'s application for child's insurance benefits; district court reversed and remanded for benefits calculation.
- Key legal question: whether B.E.B. qualifies as a 'child' under 42 U.S.C. § 402(d) by the definitions in 42 U.S.C. § 416(e) and §§ 416(h).
- Agency interpretations treat § 416(h) as the exclusive means to establish 'natural child' status under § 416(e); Beeler argues § 416(h) is only a savings clause.
- Court analyzes Iowa intestacy law to determine if B.E.B. would have inheritance rights, a prerequisite under § 416(h)(2)(A).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §416(h) is the exclusive means to qualify as a natural child under §416(e). | Beeler: §416(h) is not exclusive; undisputed biological child suffices. | Astrue: §416(h) governs natural child status; regulations require §416(h) criteria. | Agency interpretation is exclusive and reasonable; Beeler not eligible. |
| Whether the SSA interpretation is entitled to Chevron deference. | Beeler contends the regulation is ambiguous and not Chevron-controlled. | Astrue: regulations issued under authority; interpretation reasonable and controlling. | Chevron deference applies; SSA interpretation deemed reasonable. |
| Do Iowa intestacy laws confer inheritance rights to B.E.B. as an afterborn child? | Beeler asserts B.E.B. would have inheritance rights under Iowa law. | SSA/Beeler: Iowa law does not grant such rights at the time of decision. | Iowa law did not confer intestacy rights to B.E.B. at decision time. |
| Did Bruce Beeler's writing acknowledgments satisfy §416(h)(3)(C)(i)(I) to deem B.E.B. as a child? | Bruce's statements show intent to acknowledge paternity of future children. | Acknowledgments do not directly acknowledge a specific child; not sufficient. | Statements insufficient to satisfy §416(h)(3)(C)(i)(I). |
Key Cases Cited
- Schafer v. Astrue, 641 F.3d 49 (4th Cir. 2011) (affirms SSA interpretation and state intestacy framework for posthumous children)
- Gillett-Netting v. Barnhart, 371 F.3d 593 (9th Cir. 2004) (biological paternity implications debated for posthumous conception)
- Capato ex rel. B.N.C. v. Commissioner of Social Security, 631 F.3d 626 (3d Cir. 2011) (posthumous conception; SSA interpretation influencing outcome)
- Vernoff v. Astrue, 568 F.3d 1102 (9th Cir. 2009) (posthumous conception and intestacy rights discussed)
- Barnhart v. Walton, 535 U.S. 212 (U.S. 2002) (Chevron deference framework recognized)