[1][2] In 1978, the Secretary of Health and Human Services promulgated regulations in order to implement the statutory definition of disability.

The administrative law judge in her case found that by using the guidelines, there were a significant number of jobs that existed that Ms. Campbell could perform and concluded that she was not disabled.

Ms. Campbell's case was appealed to the United States Court of Appeals for the Second Circuit which reversed the decision, saying that the guidelines did not provide evidence that specific alternative jobs existed, and that the determination that Ms. Campbell was not disabled was not supported by substantial evidence as required by the Social Security Act.

In an opinion delivered by Justice Powell, the Supreme Court reversed the Second Circuit, saying that “[w]here the statute expressly entrusts the Secretary with the responsibility for implementing a provision by regulation, review is limited to determining whether the regulations promulgated exceeded the Secretary’s statutory authority and whether they are arbitrary and capricious.” The Court decided that even where an agency's enabling statute expressly required that it hold a hearing, the agency could rely on its rulemaking authority to determine issues that didn't require case-by-case considerations.

Justice Brennan concurred while pointing out that the record contained scant evidence about Ms. Campbell's ability to do "light work."