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Newman v. Shalala
No. 94-55761 (9th Cir. filed Feb. 21, 1995) ; Clearinghouse Number: 44877
Description
Challenge to HHS’s Failure to Implement the "Reliable Information" Exception to Retrospective Monthly Accounting Appealed to the Ninth Circuit
Abstract
Plaintiff-appellee SSI claimants have filed a brief in the Ninth
Circuit in this action challenging the Secretary of HHS’s
failure to promulgate a regulation implementing the "reliable
information" exception to retrospective monthly accounting
(RMA). Under RMA, the amount of SSI benefits one receives in a
given month is based on income received two months before, rather
than on income received in the current month. Plaintiffs alleged
that, under 42 U.S.C. § 1382(c)(4), HHS was required to
regulate the circumstances in which it is appropriate to make an
exception to RMA, based on "reliable information"
available on income and other circumstances for the current month.
The district court granted plaintiffs’ motion for summary
judgment and ordered HHS to issue a regulation. In response to
HHS’s appeal, plaintiffs argue that the Supreme Court’s
decision in Chevron U.S.A. v. Natural Resources Defense Council,
467 U.S. 837 (1984), neither requires nor supports judicial
deference to HHS’s construction of the statute. Plaintiffs
contend that Congress mandated that HHS promulgate a regulation
implementing the "reliable information" exception and
that HHS’s failure to do so violates its obligations under
the Administrative Procedure Act and the due process clause.
Plaintiffs also contend that the scope of the class is appropriate
and that the district court correctly tolled the statute of
limitations with respect to class members who received a final
decision from SSA more than 60 days prior to the filing of this
suit. Finally, plaintiffs argue that the district court should have
required HHS to promulgate not just a regulation but a regulation
that applies the "reliable information" exception to the
calculation of benefits in at least some cases.
