Brief Fact Summary. Appellee, Mrs. Salfi, married her husband less than six months prior to his death. Upon his death Mrs. Salfi applied for her deceased husband’s Social Security benefits, and was denied because of a rule that denies benefits to those who were married to their deceased spouse less than nine months. Mrs. Salfi then filed suit claiming that the rule in the Social Security Act does not adequately provide her due process for her loss of property right to her husband’s benefits.
Synopsis of Rule of Law. Congress has the policy choice if it so chooses to pass a generalized prophylactic rule if it finds it appropriate, even if this rule limits individualized determinations based on the rule.
Issue. Whether Congress, its concern having been reasonably aroused by the possibility of an abuse which it legitimately desired to avoid, could rationally have concluded both that a particular limitation or qualification would protect against its occurrence, and that the expense and other difficulties of individual determinations justified the inherent imprecision of a prophylactic rule?
Held. Conclude that the duration-of-relationship test meets this constitutional standard. The danger of persons entering a marriage not to enjoy the traditional benefits of such, but to enable one spouse to claim benefits upon the anticipated early death of the wage earner has been recognized since the beginning of the Social Security program. Therefore the concerns of Congress reflected in these regulations are legitimate, involving not only the integrity of the Social Security Trust Fund, but also the integrity of the marriage relationship. It is also true that the duration-of-relationship requirement operates to lessen the likelihood of abuse through sham relationships entered in contemplation of imminent death. The Court also thinks that Congress could rationally have concluded that any imprecision from which it might suffer was justified by its ease and certainty of operation. Furthermore, the administrative difficulties of individual eligibility determinations are without doubt
matters that Congress may consider when determining whether to rely on rules that sweep more broadly than the evils for which they seek to deal with. Therefore it is Congress’ policy choice to decide if this policy is best served by a prophylactic rule that is easily administered. In conclusion the Court finds no requirement for individualized determinations when Congress can rationally conclude not only that generalized rules are appropriate to its purposes and concerns, but also that the difficulties of individual determinations outweigh the marginal increments in the precise effectuation of congressional concern which they might be expected to produce.
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