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Inman v. Shalala
30 F.3d 840 (7th Cir. 1994); No. 93-2305 (7th Cir. July 19, 1994) ; Clearinghouse Number: 49608
Description
Seventh Circuit Holds That Veterans Benefits Portion Earmarked for Dependent Is Income for Purposes of Calculating Dependent’s SSI Benefits
Abstract
Reversing, the Seventh Circuit has held that the augmented portion
of a veteran’s benefits paid on behalf of a dependent is
income for purposes of calculating the dependent’s SSI
benefits. Pursuant to statute, VA pays an extra amount to veterans
with dependents. Plaintiff filed this class action when HHS reduced
her SSI benefits to take into account the augmented portion of her
husband’s veterans’ benefits. The district court held
that Social Security Ruling 82-31, which counts the augmented
portion as unearned income to the dependent, was invalid because it
was inconsistent with the statute and SSI regulations. The district
court held that, since the dependent did not necessarily have
possession of, or exercise control over, the augmented portion of
the veteran’s benefits, considering the dependent to have
"received" such payment was inconsistent with 42 U.S.C.
§ 1382a(a)(2)(B). Reversing, the Seventh Circuit held that
HHS’s interpretation of the Social Security Act was
reasonable and that the term "received" did not require
that the dependent have actual physical possession of the money.
Finding it permissible to consider the portion of a veteran’s
benefits that is earmarked for dependents to be unearned income
constructively received by the dependent, the court of appeals
deferred to HHS’s interpretation. The court reversed and
remanded with orders to the district court to enter summary
judgment for HHS.
