Law School Case Brief
Califano v. Jobst - 434 U.S. 47, 98 S. Ct. 95 (1977)
The Social Security Act is designed to provide the wage earner and the dependent members of his family with protection against the hardship occasioned by his loss of earnings; it is not simply a welfare program generally benefiting needy persons. Instead of requiring individualized proof on a case-by-case basis, Congress has elected to use simple criteria, such as age and marital status, to determine probable dependency. A child who is married or over 18 and neither disabled nor a student is denied benefits because Congress has assumed that such a child is not normally dependent on his parents. There is no question about the power of Congress to legislate on the basis of such factual assumptions. General rules are essential if a fund of this magnitude is to be administered with a modicum of efficiency, even though such rules inevitably produce seemingly arbitrary consequences in some individual cases.
An action was instituted in the United States District Court for the Western District of Missouri challenging the validity of the provisions of § 202 of the Social Security Act, 42 U.S.C.S. §§ 402, whereby secondary benefits received by a disabled dependent child of a covered wage earner terminate when the child marries a person who is not entitled to benefits under the Act, even though such person is permanently disabled, whereas such secondary benefits do not terminate if the marriage is to another person who is receiving benefits under the Act. The plaintiff, disabled by cerebral palsy since birth, had received child's insurance benefits after his father died, but the plaintiff's benefits under the Act were terminated upon his marriage to another cerebral palsy victim who was not entitled to benefits under the Act. The District Court held that § 202 deprived the plaintiff of property without due process of law. On an earlier appeal, the United States Supreme Court vacated the District Court's judgment and remanded the case for reconsideration in light of newly enacted provisions authorizing supplemental security income for the disabled (419 US 811, 42 L Ed 2d 38, 95 S Ct 26). On remand, the District Court concluded that the new statutes had no relevance to the issues in the case at bar, and reinstated its original judgment.
Was the general rule, terminating upon marriage the benefits payable to a secondary beneficiary, valid?
The Court reversed and held that the general rule, terminating upon marriage the benefits payable to a secondary beneficiary, was valid. Further, even if the benign purpose of the 1958 amendment encompassed the claimant's case, favored treatment of marriages between secondary beneficiaries did not violate the principle of equality embodied in the Due Process Clause of the Fifth Amendment.
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