Case Citator › Jan M. Sexton Salmi v. Secretary of Health and Human Services

Jan M. Sexton Salmi v. Secretary of Health and Human Services

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

Limited by some courts
Court
Sixth Circuit
Citation
774 F.2d 685
Decided
Confirmed treatments
1
Flagged citations read
342 of 342
Citing cases (total)
664
Treatment dates
1996
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Salmi v. Secretary of Health and Human Services is limited on its IQ-based disability conclusion. All 342 flagged citations have been read.
More on how this was screened

Colwell v. Chater explained that Salmi's conclusion that an IQ below 80 necessarily establishes a severe impairment rested on a Social Security ruling no longer in effect, as listed below. Later opinions continue to apply Salmi's separate rule that a published Sixth Circuit panel decision binds later panels until intervening Supreme Court or en banc authority changes it.

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.

664 later cases cite Jan M. Sexton Salmi v. Secretary of Health and Human Services; 342 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 Jan M. Sexton Salmi v. Secretary of Health and Human Services?

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Treatments

Limited

  • The Sixth Circuit declined to treat an IQ below 80 as necessarily establishing a severe impairment because the Social Security ruling underlying Salmi's conclusion was no longer in effect.

    Colwell v. Chater · Sixth Circuit · filed

    We find Colwell's argument unpersuasive. We first note that our conclusion in Salmi that an individual with an IQ of less than eighty is necessarily severely impaired rested on a Social Security Ruling no longer in effect. Moreover, there was substantial evidence in the record that the claimant in Salmi had attempted a variety of jobs, failing at each, and simply could not function in a working environment. No such evidence exists here.
    Read the full opinion on CourtListener →

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