Brown v. Apfel

Annie Lee Brown was denied widow’s Social Security benefits administratively and this denial was affirmed by the district court. The Commissioner denied benefits based on a determination that, under Mississippi law, Annie Lee Brown was never legally married to Amos Brown because Amos Brown had been previously married to Curly Mae Brown and their marriage was never terminated by divorce, annulment, or death.

The issue on appeal is whether the Social Security Administration satisfied the strenuous proof Mississippi requires to establish the invalidity of a second marriage.

Under Mississippi law,…