Califano v. Goldfarb

Brief Fact Summary. Under a federal program, widows automatically received benefits upon the death of their husbands. Widowers, however, had to prove they had been receiving support from their wives to receive benefits. A widower, upon being denied benefits, challenged the constitutionality of the distinction.

Synopsis of Rule of Law. Gender-based differentiations that lay an unequal hand upon female workers are unconstitutional, unless they are substantially related to important governmental interests.

Facts. Under the Federal Old-Age, Survivors, and Disability Insurance Benefits (OASDI) program, widows automatically received benefits upon the death of their husbands. Widowers, however, had to prove they had been receiving support from their wives before they could receive benefits. The stated purpose of the statute was to save the expenses associated with determining, which spouses were really dependants. The Appellant, Califano the Secretary of Health, Education, and Welfare (Appellant), argued that the distinction was rational because of the differing welfare needs between widows and widowers. The Appellee, Goldfard (Appellee), a widower whose wife had paid taxes into the program for 25 years, was denied benefits and sued.

Issue. Did the gender-based distinction of OASDI violate the equal protection component of the Due Process Clause of the Fifth Amendment of the United States Constitution (Constitution)?

Held. Yes. The judgment of the District Court is affirmed.
Justice William Brennan (J. Brennan) stated that the Appellee’s social security taxes were deducted from her salary for 25 years. Yet, because of the statute, she has failed to secure for her spouse the same protection similarly situated males would have secured for their spouses. In addition, she has been deprived of a portion of her earnings for the sake of contributing to a fund out of which benefits would only be paid to others. These are the results from gender-based classifications, especially when justified based on archaic and overbroad generalizations, which the Constitution forbids.
Moreover, Appellant cannot argue the statute is designed to account for the fact that women are less well off financially because of past gender discrimination (remedial legislation). The statute is phrased in terms of “dependency” not “need.”

Dissent. Justice William Rehnquist (J. Rehnquist) stated that at most this case presents a gender-based classification that favors aged widows. This is scarcely an invidious discrimination. It in no way perpetuates the economic discrimination, which forms the basis for our heightened scrutiny review of gender-based classifications.
Concurrence. Justice John Paul Stevens (J. Stevens) states that a rule leading to an unequal distribution of benefits solely on the basis of gender, is sufficiently questionable that due process requires there be a legitimate basis for presuming that the law was actually intended to serve the purpose asserted by the Government.

Discussion. This case presents an example of a gender-based classification that was arguably designed to advantage women, but that the Supreme Court of the United States (Supreme Court) found actually hurt women. Such a finding is common among cases involving gender-based distinctions.