Master Supreme Court upheld an agency’s use of medical‑vocational guidelines (the “grid”) to decide Social Security disability claims without vocational expert testimony in every case. with this comprehensive case brief.
Heckler v. Campbell is a cornerstone administrative law case about when and how agencies can use generally applicable guidelines to decide recurring factual questions in individual adjudications. In the Social Security disability context, claimants first prove they cannot perform their past work; the agency then bears the burden of showing other jobs exist in significant numbers that the claimant can do. The Social Security Administration (SSA) created “medical‑vocational guidelines”—the grid—to standardize that second step. The question was whether the agency could rely on these rules, promulgated through notice‑and‑comment rulemaking, instead of calling a vocational expert in every case.
The Supreme Court approved the practice, holding that agencies may resolve issues of “general facts” through rulemaking and then apply those rules in individual cases, so long as the rules are consistent with the statute and supported by the administrative record. At the same time, the Court cautioned that guidelines cannot be applied mechanically when a claimant’s nonexertional limitations remove them from the grid’s assumptions. The decision thus balances administrative efficiency, uniformity, and fairness, and is frequently cited both in Social Security law and in broader administrative law discussions about rulemaking versus adjudication.
461 U.S. 458 (1983)
The Secretary of Health and Human Services (Margaret Heckler), through the SSA, promulgated Medical‑Vocational Guidelines that cross‑reference a claimant’s residual functional capacity (sedentary, light, medium), age, education, and work experience to direct a disability determination (“disabled” or “not disabled”). Campbell, a disability claimant, alleged multiple impairments that prevented her from performing her past relevant work. After an administrative hearing, the Administrative Law Judge (ALJ) found that although Campbell could not return to her past work, she retained the residual functional capacity to perform a defined range of work (e.g., sedentary or light work). Rather than call a vocational expert to testify about specific jobs existing in the national economy, the ALJ applied the grid rule corresponding to Campbell’s age, education, work history, and functional capacity, and concluded she was not disabled because jobs existed that she could perform. The Appeals Council allowed the decision to stand. On judicial review, the court of appeals held that the Secretary could not rely solely on the grid to meet the agency’s burden to show job availability and that individualized vocational testimony was required in every case. The Secretary petitioned for certiorari, presenting the question whether reliance on the medical‑vocational guidelines was lawful under the Social Security Act and the Administrative Procedure Act (APA).
May the Secretary rely on medical‑vocational guidelines, adopted through rulemaking, to determine the availability of jobs in the national economy for disability claimants who fit the guidelines, without requiring individualized vocational expert testimony in every case?
An agency may use rulemaking to resolve issues of general, policy‑laden or legislative fact and apply such rules in individual adjudications, provided the rules are consistent with the governing statute, were properly promulgated, and are supported by the administrative record. In the Social Security disability context, the Secretary may rely on Medical‑Vocational Guidelines to meet the burden of showing that jobs exist in significant numbers for claimants whose age, education, work experience, and residual functional capacity match a rule, so long as the claimant’s limitations are accurately captured by the grid. The guidelines may not be applied mechanically where a claimant has significant nonexertional limitations that erode the occupational base; in such cases, additional evidence (including vocational testimony) may be required.
Yes. The Secretary permissibly relied on the medical‑vocational guidelines to determine job availability for claimants whose characteristics fit the grid, and need not produce vocational expert testimony in every case. The Court reversed the court of appeals and remanded for further proceedings consistent with this holding, emphasizing that the guidelines are inapplicable if a claimant’s nonexertional limitations are not adequately reflected in the grid.
The Court explained that the Social Security Act requires the Secretary to determine whether, considering a claimant’s age, education, and work experience, the claimant can engage in any substantial gainful work that exists in the national economy. That statutory mandate does not compel the agency to establish the existence of such jobs via case‑specific testimony in every proceeding. Under the APA, agencies have discretion to choose between rulemaking and adjudication to resolve recurring factual questions, and may rely on rulemaking to establish general propositions (e.g., that jobs exist for persons with specific exertional capacities, ages, education levels, and work histories). The SSA’s medical‑vocational guidelines are precisely such a general, data‑driven synthesis of labor‑market information and medical criteria, promulgated through notice‑and‑comment procedures. Using the grid advances uniformity and efficiency, prevents inconsistent outcomes, and avoids repetitious proof about matters amenable to generalized treatment. The Court found the guidelines consistent with the Social Security Act because they still require individualized determinations of a claimant’s residual functional capacity and other personal characteristics; the grid only comes into play after those individual facts are found. At the same time, the Court made clear that the guidelines cannot be applied mechanically where they do not account for a claimant’s significant nonexertional limitations (e.g., pain, mental, sensory, or manipulative restrictions) that may erode the occupational base indicated by the exertional level. In such circumstances, the Secretary must produce other evidence (potentially including vocational testimony) to establish that jobs exist. Thus, the guidelines are valid tools for resolving general factual issues, but they do not relieve the agency of its burden to ensure the rule fits the claimant’s actual limitations and that the overall decision is supported by substantial evidence.
Heckler v. Campbell is a leading case on agency use of rulemaking to decide recurring factual questions in individual adjudications. It validates the SSA’s medical‑vocational grid and, more broadly, teaches that agencies can rely on generally applicable, empirically based guidelines to structure decisions, so long as they are consistent with the statute, properly promulgated, and not applied mechanically to outlier cases. For law students, the case illustrates the adjudication‑versus‑rulemaking choice, the concept of legislative (general) facts, the burden‑shifting framework in disability determinations, and the limits of agency reliance on guidelines when nonexertional constraints materially affect the result.
They are SSA regulations that cross‑reference a claimant’s residual functional capacity (sedentary, light, medium), age, education, and past work experience to direct a finding of “disabled” or “not disabled.” Developed from labor‑market and medical data, the grid standardizes the agency’s showing that jobs exist for claimants with specified profiles.
No. The Court held that the Secretary may rely on the grid to meet the agency’s burden to show job availability for claimants whose limitations and vocational factors match a grid rule. Vocational testimony or other individualized evidence is necessary only when significant nonexertional limitations or other factors make the grid an inaccurate descriptor of the claimant’s occupational base.
Heckler v. Campbell confirms that agencies can resolve general, recurring factual questions through legislative rules adopted by notice‑and‑comment and then apply those rules in adjudications. The APA permits that choice so long as the rules are consistent with the statute and their application is supported by substantial evidence in individual cases.
Nonexertional limitations are restrictions not captured by strength demands—such as pain, mental impairments, environmental restrictions, manipulative or postural limits, and communication deficits. If such limitations significantly erode the range of work implicit in an exertional category, the grid cannot be applied mechanically; the agency must present additional evidence to carry its step‑five burden.
As legislative rules, the guidelines are reviewed under the APA’s arbitrary‑and‑capricious standard for validity and consistency with the statute. In an individual case, the agency’s findings—including that the claimant fits a particular grid rule and that nonexertional limits do not erode the occupational base—must be supported by substantial evidence.
It is routinely cited to support agency use of categorical rules to streamline adjudications and to distinguish between legislative facts suitable for rulemaking and adjudicative facts requiring case‑specific proof. It also informs later Social Security jurisprudence on when the grid governs and when individualized vocational evidence is necessary.
Heckler v. Campbell authorizes agencies to use empirically grounded, generally applicable guidelines to answer recurring factual questions in individual adjudications. In Social Security disability cases, that means the SSA may rely on the medical‑vocational grid to establish the existence of jobs for claimants whose characteristics match a rule, without calling a vocational expert in every case.
At the same time, the Court preserved the primacy of individualized justice by limiting mechanical grid application to cases where the claimant’s limitations are accurately reflected in the rule. When nonexertional restrictions or other factors significantly narrow the occupational base, the agency must supplement the grid with additional evidence. The case thus strikes a durable balance between administrative efficiency, uniformity, and fairness.