Frances GUGLIETTI, Plaintiff, Appellee, v. SECRETARY OF HEALTH AND HUMAN SERVICES, Defendant, Appellant

In 1978 the government began to pay the claimant social security disability benefits. In 1980 it terminated the benefits on the ground that the evidence showed she was not disabled. She sought judicial review, claiming that the termination was unlawful in the absence of a “medical improvement.” See Miranda v. Secretary of Health, Education & Welfare, 514 F.2d 996, 998 (1st Cir.1975). While her claim was pending, Congress passed a statute requiring the government to apply a “medical improvement” standard in cases such as hers. See Social Security Disability Benefits Reform Act of 1984, Pub.L.…