Astrue v. Capato

Respondent gave birth to twins conceived through in vitro fertilization using her deceased husband's frozen sperm. Respondent applied for Social Security survivors benefits for the twins, relying on 42 U.S.C. 416(e) of the Social Security Act, which defined child to mean, inter alia, "the child or legally adopted child of an [insured] individual." The Social Security Administration (SSA), however, identified subsequent provisions of the Act, sections 416(h)(2) and (h)(3)(C), as critical, and read them to entitle biological children to benefits only if they qualified for inheritance from the decedent under state intestacy law, or satisfied one of the statutory alternatives to that requirement. The Court concluded that the SSA's reading was better attuned to the statute's text and its design to benefit primarily those supported by the deceased wage earner in his or her lifetime. And even if the SSA's longstanding interpretation was not the only reasonable one, it was at least a permissible construction that garnered the Court's respect under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. View "Astrue v. Capato" on Justia Law