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Schweiker v. Chilicky

Facts of the Case

Provided by Oyez

In 1980 Congress enacted a continuing disability review (CDR) process to ensure that the only people who were receiving disability benefits under the Social Security Disability Act (Act) were those who had medical conditions sufficient to warrant such benefits. This program led to a massive increase in the number of people who were denied continuance of their benefits. The respondents were three of those people who, in addition to pursuing remedies through the uniform appeal process, sued three high-ranking administrators of the CDR process in district court. The respondents argued that the government violated their Fifth Amendment rights to due process by adopting illegal polices that led to the wrongful termination of their benefits. Despite the Act’s explicit provision of a means for remedy, the respondents sought monetary damages for their emotional distress and loss of food. The district court dismissed the case and held that the government officials were protected from paying monetary damages by the doctrine of qualified immunity. The U.S. Court of Appeals for the Ninth Circuit reversed and held that there might be enough facts to prove a violation of due process warranting monetary damages.

Questions

  1. When a government employee violates a citizen’s legal rights, should that citizen be allowed to pursue monetary damages as compensation, even when the violated statute does not contain monetary damages as a possible remedy in its remedial process?

Conclusions

  1. No. Justice Sandra Day O’Connor delivered the opinion for the 6-3 majority. The Court held that the respondents were not entitled to monetary damages because they were not mentioned in the extensive remedial options provided in the Social Security Disability Act (Act). The Court rejected the respondents’ argument that this case was analogous to Bivens v. Six Unknown Fed. Narcotics Agents, a case in which the Court ruled that, when a government actor violates a citizen’s legal right, federal courts may use any available remedy to make the wronged party whole. In Bivens there were no special circumstances preventing monetary damages, and Congress provided no legal redress in the statute. In this case, the Act provides an extensive remedial program in which Congress carefully considered the possibilities for remedy and specifically left out monetary damages.

    Justice John Paul Stevens wrote a concurring opinion in which he disagreed with the majority opinion’s decision to ignore the Solicitor General’s argument that Congress had enacted a statute expressly requiring dismissal of this complaint.

    Justice William J. Brennan, Jr. wrote a dissenting opinion in which he argued that Congressional silence on the monetary damages issue does not mean that the explicitly stated remedial process was intended to be the only source of remedy. He argued that legislators of “normal sensibilities” would have wanted some form of remedy for citizens wronged to the extent that respondents were. Justices Thurgood Marshall and Harry A. Blackmun joined in the dissent.