WOODWARD V. COMMISSIONER OF SOCIAL SECURITY 760 N.E.2d 257 (2002) CASE BRIEF

WOODWARD V. COMMISSIONER OF SOCIAL SECURITY

760 N.E.2d 257 (2002)

NATURE OF THE CASE: The United States District Court for the District of Massachusetts certified a question to the Massachusetts Supreme Court over the inheritance rights of an artificially impregnated posthumous birth child.

FACTS: Lauren (W) and Warren (H) were informed that H had leukemia. H's leukemia treatment might leave him sterile, so they arranged for a quantity of H's semen to be medically withdrawn and preserved, in a process commonly known as 'sperm banking.' H underwent a bone marrow transplant. The treatment was not successful. H died in October, 1993. In October, 1995, W gave birth to twin girls. The children were conceived through artificial insemination using the husband's preserved semen. In January, 1996, W applied for two forms of Social Security survivor benefits: 'child's' benefits under 42 U.S.C. 402(d)(1) (1994 & Supp. V 1999), and 'mother's' benefits under 42 U.S.C. 402(g)(1) (1994). W's eligibility for Social Security survivor benefits hinges on her children's eligibility for such benefits. The Social Security Administration (SSA) rejected W's claims in that she had not established that the twins were the husband's 'children' within the meaning of the Act. In October, 1996, a judge in the Probate and Family Court entered a judgment of paternity and an order to amend both birth certificates declaring H to be the children's father. W presented the judgment of paternity and the amended birth certificates to the SSA, but the agency rejected her claims again. A United States administrative law judge, hearing the wife's claims de novo, concluded, among other things, that the children did not qualify for benefits because they 'are not entitled to inherit from [the husband] under the Massachusetts intestacy and paternity laws.' The appeals council of the SSA affirmed. W appealed to the United States District Court for the District of Massachusetts, seeking a declaratory judgment to reverse the commissioner's ruling. The District Court certified a question to the Massachusetts Supreme Court.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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