Why is the case important?
Under a federal program, widows automatically received benefits upon the death of their husbands. Widowers, however, had to prove they had been receiving support from their wives to receive benefits. A widower, upon being denied benefits, challenged the constitutionality of the distinction.
Facts of the case
Leon Goldfarb was a widower who applied for survivor’s benefits under the Social Security Act. Even though his wife Hannah had paid Social Security taxes for 25 years, his application was denied. To be eligible for benefits under 42 U.S.C. Section 402, he must have been receiving half his support from his wife at her time of death. Section 402 did not impose this requirement on widows whose husbands had recently passed away. Goldfarb challenged this statute under the Due Process Clause of the Fifth Amendment in the United States District Court for the Eastern District of New York. The District Court ruled that the statute was unconstitutional. The Government appealed to the Supreme Court.
Did the gender-based distinction of OASDI violate the equal protection component of the Due Process Clause of the Fifth Amendment of the United States Constitution (Constitution)?
Yes. The judgment of the District Court is affirmed.
Justice William Brennan (J. Brennan) stated that the Appellee’s social security taxes were deducted from her salary for 25 years. Yet, because of the statute, she has failed to secure for her spouse the same protection similarly situated males would have secured for their spouses. In addition, she has been deprived of a portion of her earnings for the sake of contributing to a fund out of which benefits would only be paid to others. These are the results from gender-based classifications, especially when justified based on archaic and overbroad generalizations, which the Constitution forbids.
Moreover, Appellant cannot argue the statute is designed to account for the fact that women are less well off financially because of past gender discrimination (remedial legislation). The statute is phrased in terms of dependency not need.
The Court agreed that the sex-based distinction of 402(f)(1)(D) violated the Fifth Amendment. The dissimilar treatment for men and women who were similarly situated violated the equal protection clause. Benefits were to be distributed according to classifications that did not, without sufficient justification, differentiate among covered employees solely on the basis of sex. Appellee was entitled to recover.
- Case Brief: 1977
- Appellant: Joseph Califano, Secretary of Health, Education, and Welfare
- Appellee: Leon Goldfarb
- Decided by: Burger Court
Citation: 430 US 199 (1977)
Argued: Oct 5, 1976
Decided: Mar 2, 1977