August 01, 2014
July 31, 2014
Michigan Supreme Court to Hear Certified Question in Social Security Case
The case of Mattison v. Commissioner of Social Security, Case No. 4:05-cv-00079 (W.D. Mich.) (Enslen, J.) finds itself in an interesting place today—before the Michigan Supreme Court. The social security survivor's benefits case, which is pending before Judge Enslen in the U.S. District Court for the Western District of Michigan, is before the Michigan tribunal for resolution of a certified question of Michigan law.
The underlying case involves a claim for social security survivor's benefits for two minor children, M.M and M.M. The children were conceived by Mrs. Mattison through artificial insemination shortly after her husband's death, using sperm that had been banked by Mr. Mattison. The Social Security Administration denied the application for benefits, and an Administrative Law Judge upheld the denial. The ALJ reasoned that the children were ineligible for benefits under the Social Security Act because they could not inherit from Mr. Mattison under Michigan intestacy law. This lawsuit followed.
Under the Social Security Act, an individual who is the "child" of an insured individual and is dependent on him or her at the time of death is entitled to survivor's benefits. Whether one qualifies as a "child" depends on the laws of the state where the individual was domiciled at the time of his death. Since Mr. Mattison was domiciled in Michigan at the time of his death, Michigan law applies. Because this question is not settled under Michigan law, the parties asked Judge Enslen to certify the issue to the Michigan Supreme Court for a ruling. The Court agreed and certified the following issue:
"Whether M.M. and M.M., conceived after the death of Jeffery Mattison via artificial insemination using his sperm, can inherit from Jeffrey Mattison as his children under Michigan intestacy law."
The ruling has the potential to affect many other areas of law, not just social security benefits. But the case is particularly intriguing to court-watchers because very few Michigan Supreme Court cases come by way of certified questions from federal courts.
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