Lucretia Adams suffered from impaired vision as a result of severe diabetes. She applied for social security disability benefits. She had accumulated 32 quarters of credit from her work since 1980 and was fully insured. However, she did not have 20 quarters of credit in the 40-quarter period ending with the quarter in which her disability began and, therefore, was not specially insured. Because of this, she needed to be considered statutorily blind in order to qualify for disability benefits based upon her visual impairment.
Ms. Adams maintained a visual acuity of 20/50. In order to meet the statutory definition of blindness, a person must have a central visual of 20/200 or less in the better eye with the use of a correcting lens or have a limitation the fields of vision so that the widest diameter of the visual field subtends an angle no greater than 20 degrees, which is considered having a visual acuity of 20/200 or less in the better eye with use of a corrective lens.
Even though Ms. Adams’ visual acuity did not meet the requirements for statutory blindness, she had difficulty processing visual information when there was movement in her environment, such that she frequently tripped and fell while walking and could not see well enough to put a staple in a corner of a piece of paper. A neuropsychologist stated that she was functionally blind.
Nevertheless, Ms. Adams’ disability application was denied because she did not meet the definition for statutory blindness. She appealed.
In her appeal, Ms. Adams argued that her condition was functionally equivalent to the definition of statutory blindness. She argued that Congress could not have intended to award disability benefits to those who were functionally blind because of damage to their eyes while denying them to those with damage to their brain.
Unfortunately for Ms. Adams, the Court disagreed with her, finding that there was no basis in either the text of the statute or the legislation history to warrant anything other than a narrow, literal reading of the statute. Her benefits were denied.
See Social Security Ruling (SSR) 90-5c.