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Geduldig v. Aiello

    Brief Fact Summary. 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.

    Synopsis of Rule of Law. Underinclusive legislation is appropriate under the Equal Protection Clause, so long as the line drawn by the State is “rationally supportable.”

    Facts. California operated a disability insurance system that supplemented workers compensation, in that it provided for payments for disabilities not covered by workers compensation. The list of disabilities paid for by the State of California was not exhaustive. Among those disabilities not paid for were certain pregnancy related conditions. Suit was brought challenging the system as an unconstitutional gender-based classification.

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

    Held. 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.

    Dissent. Justice William Brennan (J. Brennan) argues that by disallowing payments related to pregnancy, the State inevitably discriminates against women.

    Discussion. The majority reaches its conclusions through viewing the problem as one of underinclusive legislation, while the dissent focuses on the inevitable connection of the unfunded conditions with a single sex.


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