8th Circuit: Child conceived through artificial insemination more than a year after her father’s death not entitled to SSA benefits

Beeler v. Astrue, No. 10-1092 (8th Cir. Aug. 29, 2011)

The Social Security Act authorizes the payment of benefits to the dependent children of deceased workers.  This case requires us to determine whether a child conceived through artificial insemination more than a year after her father’s death qualifies  for  benefits  under  the  Act.  The Commissioner  of the  Social Security Administration (“SSA”) interprets  the  Act  to provide that a  natural child  of thedecedent is not entitled to benefits unless she has inheritance rights under state lawor can satisfy certain  additional statutory  requirements.  We  conclude that the Commissioner’s interpretation is, at a minimum, reasonable and entitled to deference, and that the relevant state law does not entitle the applicant in this case to benefits. We therefore reverse the district court’s contrary judgment.