Powell v. Heckler

Summary

The Eleventh Circuit reviewed the partial denial of Title II Social Security disability benefits to William V. Powell. The court held that the administrative decision did not properly apply the sequential evaluation regulations and was not supported by substantial evidence for periods when Powell was not engaged in substantial gainful activity. It affirmed benefits from December 31, 1981, reversed the denial for earlier periods, and remanded with instructions to award benefits for periods from 1978 through 1981 when Powell was not engaged in substantial gainful activity.

Holdings

1. The sequential disability-evaluation method required by 20 C.F.R. § 404.1520 must be followed when evaluating a claim for disability benefits, and failure to follow it constitutes grounds for reversal.
2. A person otherwise disabled under Title II who engages in substantial gainful activity passes into and out of eligibility for benefits when beginning or ceasing such activity; substantial gainful activity bars benefits only for the periods during which it occurs.
3. Powell was eligible for disability benefits for periods from 1978 through 1981 during which his income was below the substantial-gainful-activity threshold, subject at most to the approximately ten-week period in late 1981 when his earnings exceeded that threshold.

Questions Presented

1. Whether the Secretary and the lower court properly applied the sequential disability-evaluation method required by 20 C.F.R. § 404.1520.
2. Whether intermittent employment or earnings below the substantial-gainful-activity threshold barred disability benefits during periods when Powell was otherwise disabled.
3. Whether substantial evidence supported denying benefits for the period from 1978 through October 26, 1981.

Disposition

reversed_and_remanded