Califano v. Jobst

Supreme Court of the United States · Family Law

Family LawSocial SecurityEqual protection component of Fifth Amendment due processmarriage as terminating eventchild's insurance benefitssecondary beneficiariesprobable dependencyadministrative efficiency

Facts

Mr. Jobst had been disabled by cerebral palsy since birth and qualified for child's insurance benefits after his father's death. In 1970 he married another person with cerebral palsy. Because his wife was not entitled to benefits under the Social Security Act, the statute required termination of his benefits upon marriage. The challenged statutory scheme generally terminated a dependent child's benefits at marriage, but a 1958 amendment preserved benefits when the beneficiary married another person already entitled to specified Social Security benefits.

Issue

May Congress require termination of a dependent child's Social Security benefits upon marriage even when the spouse is permanently disabled and unable to provide support? More specifically, does the Fifth Amendment invalidate the general marriage-termination rule because Congress created a limited exception for marriages between beneficiaries?

Rule

In the Social Security system, Congress may rely on simple, administrable classifications such as marital status to determine probable dependency rather than require individualized proof of need or dependency. A marriage-based termination rule for secondary benefits is constitutionally valid if rationally related to probable economic independence, and a limited exception for marriages between beneficiaries is also valid when it rests on a reasonable predicate and serves administrability and hardship-reduction goals.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Lena Ortiz receives a federal secondary insurance benefit as the adult disabled child of a deceased wage earner. Congress amends the program to end that benefit when the recipient marries, even if the new spouse has little income and Lena remains in fact dependent on her late parent’s earnings history.

If Lena argues that the Fifth Amendment requires the government to keep paying her because she is actually still dependent, what is the strongest response?

Explanation. The majority upheld use of marital status as a simple, administrable criterion for probable dependency. In this kind of social insurance scheme, Congress need not condition eligibility on actual need or actual dependency in every case. A general marriage-termination rule is valid if rationally related to probable economic independence, even though some individuals remain dependent.