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Schweiker v. Wilson

Supreme Court of the United States · 1981 · Constitutional Law

Constitutional LawEqual ProtectionFifth AmendmentSocial Welfare BenefitsSSISupplemental Security IncomeMedicaidpublic institution

Facts

Congress created the SSI program to provide subsistence benefits to needy aged, blind, and disabled persons, but it generally excluded any person who is an inmate of a public institution. Congress made a partial exception allowing a small reduced benefit to otherwise eligible persons residing in certain institutions receiving Medicaid payments for their care. Because Medicaid does not fund care for persons aged 21 through 64 in public mental institutions, otherwise eligible members of that group could not receive the reduced SSI stipend. Appellees, members of that excluded group, argued that the exclusion violated the equal protection component of the Fifth Amendment's Due Process Clause.

Issue

May Congress constitutionally deny reduced SSI benefits to otherwise eligible persons aged 21 through 64 who are institutionalized in public mental institutions that do not receive Medicaid funds for their care? More specifically, is the SSI classification tied to Medicaid eligibility unconstitutional under the equal protection component of the Fifth Amendment?

Rule

Unless a federal statute employs an inherently invidious classification or impinges on fundamental rights, it is reviewed under rational basis scrutiny and will be upheld if the classification is rationally related to legitimate governmental objectives. In the social welfare context, Congress may draw imperfect lines, and courts will not substitute their policy preferences so long as the classificatory scheme rationally advances a reasonable and identifiable governmental objective.

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

Congress creates a federal personal-expense stipend for indigent disabled adults living in public institutions. The statute gives the stipend only to residents of facilities that receive federal medical reimbursements for that resident's care, and residents of a state psychiatric center in Columbus, Ohio receive nothing because their care is not federally reimbursed. Several residents sue, arguing the law targets people with schizophrenia and therefore deserves heightened scrutiny.

How should a court most likely analyze the classification under the majority's approach?

Explanation. The majority first asks whether the statute employs an inherently invidious classification or impinges on a fundamental right. If not, rational basis applies. A federal benefits rule tied to whether the institution receives federal medical payments for the individual's care is treated as a funding-status classification, even if it incidentally affects many mentally ill persons. Because the statute does not directly classify on the basis of mental health, heightened scrutiny is not triggered.