Law School Case Brief
Geduldig v. Aiello - 417 U.S. 484, 94 S. Ct. 2485 (1974)
Consistently with the equal protection clause, a state may take one step at a time, addressing itself to the phase of the problem which seems most acute to the legislative mind. The legislature may select one phase of one field and apply a remedy there, neglecting the others. Particularly with respect to social welfare programs, so long as the line drawn by the state is rationally supportable, the courts will not interpose their judgment as to the appropriate stopping point. The equal protection clause does not require that a state must choose between attacking every aspect of a problem or not attacking the problem at all.
Appellee Aiello and several other women became pregnant and suffered employment disabilities as a result of their pregnancies. With respect to three appellees, Carolyn Aiello, Augustina Armendariz, and Elizabeth Johnson, the disabilities were attributable to abnormal complications encountered during their pregnancies. The fourth, Jacqueline Jaramillo, experienced a normal pregnancy, which was the sole cause of her disability. Appellees were subject to a mandatory state employment tax to fund a disability insurance program, and they filed suit in federal district court claiming that the program violated the Fourteenth Amendment because it precluded the payment of benefits for any disability resulting from pregnancy. The district court determined that the program violated the equal protection clause of U.S. Const. amend. XIV and enjoined its continued enforcement. Appellant Geduldig, the Director of the Department of Human Resources Development, sought review of the decision.
Did the state disability insurance program violate the equal protection clause of U.S. Const. amend. XIV?
The Supreme Court of the United States held that the exclusion of benefits due to disability from pregnancy did not result in invidious discrimination under the Equal Protection Clause. The Court found that the program did not discriminate with respect to the persons or groups that were eligible for disability insurance protection under the program. The Court held that the challenged classification related to the asserted underinclusiveness of the set of risks that the state had selected to insure. The Court determined that although the state had created a program to insure most risks of employment disability, it was not required to insure all such risks based upon the minimal amount collected from each participating citizen.
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