Weinberger v. Salfi
422 U.S. 749 (1975)
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Rule of Law:
In the area of social welfare, a legislative classification does not violate the Due Process Clause of the Fifth Amendment if it is rationally related to a legitimate legislative goal. Congress may use prophylactic, bright-line eligibility rules, even if they operate as conclusive presumptions and are over- or under-inclusive, to promote administrative efficiency and prevent fraud.
Facts:
- Appellee Salfi married Londo L. Salfi on May 27, 1972.
- Londo Salfi was allegedly in apparent good health at the time of the marriage.
- Less than one month after the marriage, Londo Salfi suffered a heart attack.
- Londo Salfi died on November 21, 1972, less than six months after the marriage.
- Appellee Salfi had a daughter, Doreen Kalnins, from a previous marriage.
- Salfi applied for mother's insurance benefits for herself and child's insurance benefits for her daughter, based on her deceased husband's earnings.
- The Social Security Administration denied the applications solely because Salfi's relationship to the deceased wage earner did not meet the nine-month duration requirement mandated by the Social Security Act.
Procedural Posture:
- Appellee Salfi filed applications for mother's and child's insurance benefits with the Social Security Administration (SSA).
- The SSA denied the applications at both the initial and reconsideration stages, based on the statutory nine-month duration-of-relationship requirement.
- Salfi filed a class-action lawsuit in the United States District Court for the Northern District of California against the Department of Health, Education, and Welfare and its officials.
- A three-judge District Court was convened, which certified a class action and granted summary judgment for Salfi.
- The District Court issued a declaratory judgment that the duration-of-relationship requirements were unconstitutional and enjoined the government from enforcing them.
- The government officials (appellants) filed a direct appeal to the Supreme Court of the United States.
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Issue:
Does the Social Security Act's requirement that a marriage must have lasted at least nine months prior to a wage earner's death for the surviving spouse and stepchildren to be eligible for survivor's benefits violate the Due Process Clause of the Fifth Amendment?
Opinions:
Majority - Justice Rehnquist
No, the nine-month duration-of-relationship requirement does not violate the Due Process Clause of the Fifth Amendment because it is a rational means for Congress to prevent sham marriages undertaken to obtain Social Security benefits. The standard for testing classifications in social welfare legislation is whether the statute manifests a patently arbitrary classification, utterly lacking in rational justification. The line of cases invalidating 'irrebuttable presumptions,' such as Stanley v. Illinois and Vlandis v. Kline, are not controlling because they involved fundamental rights or state-defined statuses, whereas a noncontractual claim to government benefits does not enjoy the same constitutionally protected status. The nine-month requirement is a prophylactic rule designed for administrative ease and to prevent fraud. Congress could rationally conclude that the expense and difficulty of individualized hearings to determine the motive of each marriage justify the imprecision of a bright-line rule. This legislative choice is consistent with the deferential standard of review applied to economic and social welfare legislation.
Dissenting - Justice Douglas
Yes, the requirement unconstitutionally deprives an individual of the right to prove the genuineness of their marriage. The statutory presumption that a marriage of less than nine months is a sham for the purpose of obtaining benefits invades the right to a jury trial. The genuineness of a marriage is a question of fact that should be decided in an appropriate hearing. Therefore, the case should be remanded to give Mrs. Salfi an opportunity to show that her marriage was legitimate and not entered into for the purpose of securing benefits.
Dissenting - Justice Brennan
Yes, the nine-month requirement is an unconstitutional irrebuttable presumption that violates the Due Process Clause. This holding is flatly contrary to recent decisions in Vlandis v. Kline and U.S. Dept. of Agriculture v. Murry, which struck down similar conclusive presumptions in government benefit programs. The majority's attempt to distinguish those cases is unpersuasive. The presumption here is irrational, as there is no evidence that collusive marriages are a significant problem. The government's interest in administrative efficiency should not override an individual's right to prove that the presumed fact—that the marriage is a sham—is untrue, especially when the presumption carries a measure of social opprobrium. The claimant should be afforded an individual hearing to prove the marriage was entered into in good faith.
Analysis:
This decision marked a significant retreat from the expanding 'irrebuttable presumption' doctrine, re-establishing a strong presumption of constitutionality for social and economic legislation. The Court clarified that unless a fundamental right is at stake, Congress has broad latitude to use prophylactic, bright-line rules for administrative convenience, even if those rules are not perfectly tailored to the legislative goal. This holding solidified the use of a highly deferential rational basis standard for classifications in social welfare programs, limiting the judiciary's role in second-guessing legislative line-drawing in this area. It effectively insulated many eligibility requirements in federal benefit programs from constitutional challenges based on Due Process.
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