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.
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.”
The mere recitation of a benign, compensatory purpose is not an automatic shield which protects against any inquiry into the actual purposes underlying a statutory scheme.View Full Point of Law