After-death child benefits
Astrue v. Karen K. Capato, on Behalf of B. N. C.
In brief
The Supreme Court backed the Social Security Administration’s interpretation, overturned the Third Circuit, and sent the case back without deciding whether the twins qualified under state inheritance law.
- Where it stands
- Decided
Decided · May 21, 2012 · Opinion by Justice Ginsburg
- What it’s about
- The Supreme Court ruled that the Social Security Administration could use state inheritance law to decide whether Karen Capato’s twins, conceived after their father’s death, qualified for survivor benefits.
- Who it affects
- The ruling approved the agency’s interpretation but did not settle whether the twins qualify under the relevant state inheritance law.
Summary: written with AI from the case record.
What it's about
It overturned the Third Circuit’s ruling and sent the case back to the lower court (remanded), without deciding the twins’ status under the relevant state law.
The dispute turned on whether children conceived after a worker’s death count as that worker’s children for Social Security survivor benefits.
Question presented
Are Karen K. Capato's twins - conceived by in vitro fertilization after their biological father's death - "child(ren)" under Title II of the Social Security Act?
What the Court decided
Holding
The SSA’s reading is 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. Moreover, even if the SSA’s longstanding interpretation is not the only reasonable one, it is at least a permissible construction entitled to deference under Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., 467 U. S. 837. Pp. 4– 16. 631 F. 3d 626, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said the agency’s reading fit the law’s words and its aim of helping people the deceased worker supported while alive. It added that the reading was reasonable enough for the agency to use, even if it was not the only reasonable one.
The vote
- Majority author
- Ruth Bader Ginsburg
What's next
The case returns to the Third Circuit for further proceedings under the Supreme Court’s ruling. Whether the twins qualify under state inheritance law remains unresolved.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Case Briefing
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Audio Recording added: Oral Arguments - Astrue
Opinion added: Astrue
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.