Califano v. Jobst
1977 U.S. LEXIS 154, 54 L. Ed. 2d 228, 434 U.S. 47 (1977)
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Rule of Law:
A legislative classification in a social welfare program, such as terminating a dependent child's Social Security benefits upon marriage to a non-beneficiary, does not violate the equal protection component of the Fifth Amendment's Due Process Clause so long as it is rationally related to a legitimate government interest.
Facts:
- Mr. Jobst had been disabled by cerebral palsy since birth.
- In 1957, following his father's death, he began receiving child's insurance benefits under the Social Security Act.
- In 1970, Mr. Jobst married another individual who was also a victim of cerebral palsy.
- Mr. Jobst's wife was not receiving Social Security benefits at the time of their marriage.
- Pursuant to the Social Security Act, the Secretary terminated Mr. Jobst's benefits because he married a non-beneficiary.
Procedural Posture:
- After the Secretary terminated Mr. Jobst's benefits, he exhausted his administrative remedies.
- Mr. Jobst sued the Secretary in U.S. District Court to review the termination of his benefits.
- The District Court held that the statutory provisions were unconstitutional, finding they violated the equal protection component of the Fifth Amendment.
- The Secretary (appellant) appealed directly to the U.S. Supreme Court.
- The Supreme Court remanded the case for the District Court to reconsider in light of a new supplemental security income program.
- On remand, the District Court reinstated its original judgment finding the statute unconstitutional.
- The Secretary (appellant) again appealed to the U.S. Supreme Court, which noted probable jurisdiction.
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Issue:
Does the Social Security Act, which terminates a dependent child's benefits upon marriage to a non-beneficiary but not upon marriage to another beneficiary, violate the equal protection component of the Fifth Amendment's Due Process Clause?
Opinions:
Majority - Mr. Justice Stevens
No, the Social Security Act's distinction regarding whom a beneficiary marries does not violate the Fifth Amendment's Due Process Clause. Congress may use general, administratively efficient rules based on rational assumptions, even if they produce seemingly arbitrary results in individual cases. The general rule terminating benefits upon marriage is valid because marriage is a rational proxy for a change in economic status and dependency. The exception for marriages between two beneficiaries is also rational, as it was designed to prevent the 'dual hardship' of both spouses losing their benefits simultaneously. Congress is permitted to address a problem incrementally and is not required to create a perfect, all-encompassing solution.
Analysis:
This decision solidifies the Court's application of rational basis review to classifications within social welfare legislation, affording significant deference to Congress. It affirms the principle that Congress can use prophylactic, easily administrable rules (like marital status) as a proxy for more complex inquiries (like actual dependency) to manage large benefit programs. The case establishes that even if a classification is underinclusive, it will be upheld if Congress takes 'one firm step' toward a legitimate goal, reinforcing that legislative bodies need not solve an entire problem at once.
