| Abstract: | The Social Security Administration promulgated the medical-vocational guidelines (the grid) in 1978 in order to improve consistency and efficiency in disability claim adjudications. The grid takes administrative notice of the availability of jobs suited to claimants' capabilities, eliminating the need to make such a determination on a case-by-case basis. In Heckler v. Campbell, the Supreme Court held that the grid is valid and that the Secretary of Health and Human Services cannot be required to give specific examples of jobs available in the national economy. In so doing, the Court reversed the Second Circuit, which had required the Secretary to give claimants examples of jobs suited to their individual characteristics to assure them adequate notice of the issues involved in their hearings. This Case Comment contends that the Supreme Court misperceived the Second Circuit's purpose in requiring the Secretary to provide specific examples of available jobs. Nonetheless, the Comment argues that the Supreme Court decision does not foreclose requiring such examples to assure adequate notice and to aid in resolving adjudicative factual issues. This Comment concludes that such a requirement would improve the efficiency, accuracy and consistency of Social Security disability determinations. |
