Califano v. Webster Case Brief

Why is the case important?

The Social Security old-age insurance benefits are calculated differently for men and women, with the result that women’s benefits are skewed slightly toward their later (higher earning) years, qualifying women for slightly greater benefits.

Facts of the case

Question

Is this disparity of methods between sexes proper under the Fifth Amendment of the United States Constitution (Constitution)?

Answer

No. The Supreme Court of the United States (Supreme Court) reiterates the holding of Craig v. Boren, 429 U.S. 190 (1976), saying that a classification based on gender must serve an important government interest and be substantially related to achieving that interest. Citing the historical wage gap between men and women, the Supreme Court views that allowing women to eliminate three low-wage years from their calculation, remedies some part of this discrimination.

Conclusion

The Court held that old-age benefit payments were not constitutionally immunized against alterations of the kind at issue in the case and that Congress was authorized to replace one constitutional computation formula with another and to make the new formula prospective only. The former version of the challenged statute operated directly to compensate women for past economic discrimination and was deliberately enacted to compensate women for the particular economic disabilities they suffered. The subsequent amendment of § 415 was not a Congressional admission that its previous policy was invidiously discriminatory. The retired male worker’s Fifth Amendment rights were not violated by the prospective application of § 415 , as the Constitution did not forbid statutory changes to have a beginning and thus to discriminate between the rights of an earlier and later time.

  • Case Brief: 1977
  • Appellant: Califano
  • Appellee: Webster
  • Decided by: Burger Court

Citation: 430 US 313 (1977)
Decided: Mar 21, 1977