Ruth Wengler died in a work-related accident while employed by Dicus Prescription Drugs, Inc. Her husband, Paul Wengler, sought death benefits under Missouri's workers' compensation statute, which granted widows a conclusive presumption of dependency but required widowers to prove either incapacity from wage earning or actual dependence on their wives' earnings. Wengler stipulated that he was neither incapacitated nor dependent on his wife's earnings. He argued that the statute's different treatment of widows and widowers violated the Equal Protection Clause.
Issue
Does a Missouri workers' compensation statute violate the Equal Protection Clause by automatically granting death benefits to widows while requiring widowers to prove incapacity or actual dependency before receiving the same benefits?
Rule
Under the Equal Protection Clause, gender-based discriminations must serve important governmental objectives, and the discriminatory means employed must be substantially related to achieving those objectives. A bare claim of administrative convenience is insufficient to justify a statutory sex-based distinction without a persuasive showing that equal treatment would cause the asserted administrative or economic problems.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Ohio's public-utilities death-benefit statute pays automatic survivor benefits to a deceased lineworker's widow. A widower receives the same benefits only if he proves he was actually dependent on his wife's wages when she died. After his wife is killed on the job in Cleveland, Daniel Mercer applies but cannot show dependency.
If Daniel challenges the statute under the Equal Protection Clause, which is the strongest argument that the statute is unconstitutional?
Explanation. The majority held that gender-based classifications must serve important governmental objectives and must be substantially related to those objectives. Helping needy spouses is an important objective, but a law that automatically benefits widows while requiring widowers to prove dependency is unconstitutional when the State offers only a generalization about typical dependency patterns. The Court emphasized that equal treatment could be achieved either by paying all surviving spouses or by requiring individualized proof from all. It also rejected the idea that employer-funded benefit systems receive a different equal protection standard.