Case Citator › Boyd v. Heckler

Boyd v. Heckler

Is it still good law? What later courts have actually done to this case.

Superseded by statute
Court
Eleventh Circuit
Citation
704 F.2d 1207
Decided
Confirmed treatments
1
Flagged citations read
31 of 31
Citing cases (total)
31
Treatment dates
1991

Status

Superseded by statute
A reviewed court treats this case as superseded by later legislation. Boyd v. Heckler's rule allowing disability to be proved by subjective pain testimony alone was superseded by statute. In Elam v. Railroad Retirement Board, the Eleventh Circuit explained that Congress had replaced that rule with a standard requiring medical evidence of an underlying condition.
More on how this was screened

Although the statutory amendment later expired, Elam held that the older rule did not return because the agency regulations continued to require an underlying medical condition. All 31 flagged citations have been read. Later courts continued to apply Boyd's separate holdings on review for legal error, retrospective medical opinions, and remand when factual issues remain; the confirmed statutory treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

31 later cases cite Boyd v. Heckler; 31 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Boyd v. Heckler?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Superseded by statute

  • The Eleventh Circuit held that Congress's amendment to the Social Security Act displaced Boyd's rule permitting disability based on subjective pain testimony alone.

    Elam v. Railroad Retirement Board · Eleventh Circuit · filed

    We acknowledged in Hand that the amendments overturned Boyd, 704 F.2d 1207, Simpson, 691 F.2d 966, and other decisions that had permitted proof of disability by subjective pain testimony alone. Hand, 761 F.2d at 1548, n. 4. We also recognized that when Congress passed § 423(d)(5)(A) it intended to codify the existing regulations and to establish a uniform standard that required that a finding of disability be based on verifiable evidence.
    Read the full opinion on CourtListener →

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