Heckler v. Matthews

LOCATION: A&P supermarket

DOCKET NO.: 82-1050
DECIDED BY: Burger Court (1981-1986)

CITATION: 465 US 728 (1984)
ARGUED: Dec 05, 1983
DECIDED: Mar 05, 1984

John R. Benn - Argued the cause for the appellees
Mark Irving Levy - Argued the cause for the appellant

Facts of the case

Congress responded to the Court's decision in Califano v. Goldfarb (1977), which invalidated a gender-based dependency requirement in the allocation of Social Security payments, and to the necessity of preventing bankruptcy in the Social Security fund. It enacted amendments in 1977 to the Social Security Act. The 1977 amendments included a "pension offset" provision which reduced spousal benefits by the amount of certain federal and state pension funds that a Social Security applicant received. However, Congress exempted from this provision spouses who were eligible to receive pension benefits prior to December 1982 and who would have qualified for unreduced spousal benefits prior to the Court's Califano decision.


Did the resurrection of pre-California law which allowed some gender-based classification in Social Security allocations violate the Due Process Clause of the Fifth Amendment?

Media for Heckler v. Matthews

Audio Transcription for Oral Argument - December 05, 1983 in Heckler v. Matthews

Warren E. Burger:

Mr. Levy, you may proceed whenever you are ready.

Mark Irving Levy:

Thank you, Mr. Chief Justice, and may it please the Court:

This case is here on direct appeal to the United States District Court for the Northern District of Alabama.

It involves the government pension offset section in the Social Security Amendments of 1977 and in particular the exception and severability provisions in the offset section.

The District Court, after certifying a nationwide class action, invalidated both the exception and the severability provisions.

Based on those rulings, the District Court extended spousal benefits or expanded the exception to Appellee and the nationwide class of non-dependent men he represents, and as a result, it entitled those non-dependent men to the receipt of both government pension and Social Security spousal benefits.

The Social Security provides spousal benefits--

Was that judgment stayed?

Mark Irving Levy:

--The judgment was stayed pending appeal to this Court and it remains stayed.


Mark Irving Levy:

The Social Security Act provides spousal benefits based on the earnings record of the applicant's spouse.

The provisions for wives' and widows' benefits were enacted in 1939, the provisions for husbands' and widowers' benefits in 1950.

From the time spousal benefits were first established, the Act has contained a Social Security offset provision.

That provision requires that were an applicant is entitled to more than one benefit under the Social Security Act, those benefits will be offset against each other so that in net effect the recipient or the applicant will receive only the higher of the two benefits.

For example, if an applicant is entitled to spousal benefits and also to retirement benefits based on his own work account, the spousal benefits will be reduced by the amount of the direct benefit to which the applicant is entitled.

Until the statute at issue in this case, the Act contained no comparable provision for people, primarily government employees, who worked in employment that was not covered by the Social Security system.

In March 1977, this Court decided the Goldfarb case and invalidated the gender-based eligibility standard in the Social Security Act that required men, but not women, to prove dependency in order to be eligible for spousal benefits.

As a result of Goldfarb, spousal benefits, therefore, were extended to non-dependent men.

In practice, this did not--

Who extended it?

Mark Irving Levy:

--I don't believe that the issue of extension versus nullification was ever directly litigated in this Court.

Byron R. White:

Who extended it, the Secretary or--

Mark Irving Levy:

Believing that that to be the result that follows from the decision of this Court, the benefits were extended.

That, in practice, did not prove to be a problem for the Social Security Trust Fund with respect to non-dependent men who worked in employment covered by Social Security.

Those men usually were entitled to higher benefits on their own work account than on the account of their spouse.

Because the Social Security Act has an eligibility requirement providing that a spousal applicant must have no or only minimal benefits in his own account and because of the offset, the Social Security offset provision that already existed in the Act, in fact, no spousal payments were generally made to this group of non-dependent men.

It was a far different situation, however, for non-dependent men who worked in employment that was not covered by Social Security.

As to this group, spousal benefits, in fact, were payable, and because they were not subject to the existing Social Security offsets, since they weren't employed in work covered by Social Security, those spousal payments were the full, unreduced amount and were not adjusted in any way to reflect their government pension.

This caused a windfall for this group of non-dependent men.

Because they did not meet the eligibility standards set out by Congress in the Social Security Act, they did not expect to receive spousal benefits and they could not have planned their retirements in reliance on the receipt of such benefits.