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Keywords

plaintiffdiscriminationdue process

hearingdue processappellee

Related Cases

Califano v. Webster, 430 U.S. 313, 97 S.Ct. 1192, 51 L.Ed.2d 360

Facts

The plaintiff, a male wage earner, filed suit against the Secretary of Health, Education, and Welfare, arguing that the Social Security Act's provision allowing women to exclude three more lower-earning years from their benefit calculations was unconstitutional. Prior to a 1972 amendment, the number of 'elapsed years' for men was three higher than for women, resulting in women receiving slightly higher benefits. The District Court ruled that this scheme violated the equal protection component of the Due Process Clause of the Fifth Amendment.

A single-judge District Court for the Eastern District of New York, on review under s 205(g) of the Social Security Act, 42 U.S.C. s 405(g), of a denial, after hearing, of appellee's request that the more favorable formula be used to compute his benefits, held that, on two grounds, the statutory scheme violated the equal protection component of the Due Process Clause of the Fifth Amendment.

Issue

Did the provision of the Social Security Act that allowed female wage earners to exclude more low-earning years from their benefit calculations than male wage earners violate the equal protection component of the Due Process Clause of the Fifth Amendment?

Rule

Classifications by gender must serve important governmental objectives and must be substantially related to the achievement of those objectives, particularly in the context of remedying past discrimination.

To withstand scrutiny under the equal protection component of the Fifth Amendment's Due Process Clause, ‘classifications by gender must serve important governmental objectives and must be substantially related to achievement of those objectives.’

Analysis

The Supreme Court analyzed the provision under the framework of equal protection, determining that the differing treatment of male and female wage earners was aimed at addressing the historical economic disadvantages faced by women. The court found that the provision was not based on outdated stereotypes but was a legitimate effort to compensate for past discrimination, thus satisfying the requirements for gender classifications under the Fifth Amendment.

The statutory scheme involved here is more analogous to those upheld in Kahn and Ballard than to those struck down in Wiesenfeld and Goldfarb. The more favorable treatment of the female wage earner enacted here was not a result of ‘archaic and overbroad generalizations' about women, or of ‘the role-typing society has long imposed’ upon women, such as casual assumptions that women are ‘the weaker sex’ or are more likely to be child-rearers or dependents.

Conclusion

The Supreme Court reversed the lower court's ruling, holding that the provision allowing women to exclude additional low-earning years from their benefit calculations was constitutional and served a legitimate governmental purpose.

Reversed.

Who won?

The Secretary of Health, Education, and Welfare prevailed in the case as the Supreme Court upheld the constitutionality of the Social Security Act provision.

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