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Heckler v. Mathews

Supreme Court of the United States · 1984 · Constitutional Law

Constitutional LawEqual ProtectionStandingSocial SecurityFifth Amendmentequal protection component of due processgender discriminationintermediate scrutiny

Facts

Before 1977, wives and widows could receive Social Security spousal benefits without proving dependency, but husbands and widowers had to show dependency on their wives for one-half of their support. After Goldfarb invalidated that gender-based dependency requirement, Congress repealed the dependency requirement but also enacted a pension-offset provision reducing spousal benefits by the amount of certain government pensions, along with a temporary exception for persons who would have qualified under the law as it was administered in January 1977. That exception effectively preserved for a five-year grace period the old rule that nondependent women, but not nondependent men, could avoid the offset. Robert Mathews, a retired Postal Service employee with a government pension, applied for husband's benefits in December 1977 and was told his benefits were entirely offset because he was not dependent on his wife.

Issue

Did Mathews have standing to challenge the pension-offset exception even though the statute's severability clause would prevent extension of the exception to him? And if so, did the temporary exception to the pension-offset provision, which revived a gender-based dependency distinction for a limited period, violate the equal protection component of the Fifth Amendment?

Rule

A person denied equal treatment on the basis of sex suffers a cognizable constitutional injury, and standing does not depend on the availability of increased monetary benefits because that injury may be redressed either by extending benefits to the excluded class or by withdrawing benefits from the favored class. Gender-based classifications must be supported by an exceedingly persuasive justification, meaning they must serve important governmental objectives and the discriminatory means employed must be substantially related to achieving those objectives. Protecting reasonable reliance interests in prior law is an important governmental objective and can justify a temporary gender-based classification when the classification is narrowly tailored to protect those who planned their retirements in reliance on the prior regime.

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

Congress creates a federal retirement supplement for spouses of municipal employees. A transition provision exempts applicants who would have qualified under January 2025 rules, which required husbands, but not wives, to prove financial dependence. In Phoenix, Daniel Ortiz is denied the exemption because he cannot show dependence on his wife, and the statute also says that if the exemption is invalidated, it may not be extended to anyone else.

If Daniel sues on equal protection grounds, is redressability most likely satisfied?

Explanation. The governing rule is that a plaintiff denied equal treatment on the basis of sex suffers a cognizable constitutional injury. Redressability does not depend on the plaintiff's receiving more money, because the injury may be remedied either by extending benefits to the excluded class or by nullifying the favored treatment. A legislative clause preferring nullification over extension does not defeat standing so long as equal treatment can still be achieved by withdrawal of the preference.