Geduldig v. Aiello Case Brief

Why is the case important?

California operated a disability insurance system that paid benefits to employees of private employers when workers compensation did not cover certain disabilities that prevented those employees from working. However, many pregnancy related disabilities were excluded from coverage because of expenses to the program.

Facts of the case

Carolyn Aiello experienced disability as a result of complications during her pregnancy. She was ineligible for benefits from California’s Disability Fund under Section 2626 of California’s Unemployment Insurance Code. Section 2626 denied benefits to women whose disabilities resulted from pregnancy. Aiello and other disabled women who were denied benefits under Section 2626 challenged the statute as a violation of the Equal Protection Clause of the Fourteenth Amendment. The United States District Court for the Northern District of California held the statute unconstitutional. The state appealed to the Supreme Court.

Question

Does the exclusion of the pregnancy-related conditions violate the Fourteenth Amendment’s Equal Protection Clause?

Answer

No. Appeals Court ruling affirmed.
The list of conditions covered by the disability insurance system is not exclusive. Furthermore, there are conditions not covered by the system that affect both men and women. The excluded conditions do not affect women alone.
The savings given the program by the exclusion of such conditions benefit both men and women. That is, inclusion of the excluded conditions would result in lesser amounts of funding for all other conditions.

Conclusion

The Supreme Court of the United States held that the exclusion of benefits due to disability from pregnancy did not result in invidious discrimination under the Equal Protection Clause . The Court found that the program did not discriminate with respect to the persons or groups that were eligible for disability insurance protection under the program. The Court held that the challenged classification related to the asserted underinclusiveness of the set of risks that the state had selected to insure. The Court determined that although the state had created a program to insure most risks of employment disability, it was not required to insure all such risks based upon the minimal amount collected from each participating citizen.

  • Case Brief: 1974
  • Appellant: Geduldig, Director, Department of Human Resources Development
  • Appellee: Carolyn Aiello et al.
  • Decided by: Burger Court

Citation: 417 US 484 (1974)
Argued: Mar 26, 1974
Decided: Jun 17, 1974