## Facts

- John A. Jobst, born in 1932, was disabled by cerebral palsy.
- After his father’s death, Jobst qualified for Social Security “child’s insurance” benefits as a disabled dependent child.
- The Social Security Act generally terminated a disabled dependent child’s secondary benefits upon marriage.
- The Act created an exception allowing benefits to continue if the disabled child married someone “entitled to benefits” under the Act.
- In 1970, Jobst married a person with cerebral palsy who was not entitled to Social Security benefits.
- Because his spouse was not a beneficiary, the Secretary terminated Jobst’s benefits.
- Jobst challenged the termination as violating the equality component of the Fifth Amendment’s Due Process Clause.

## Issues

1. Whether Congress may terminate a disabled dependent child’s Social Security benefits upon marriage to a spouse not entitled to benefits under the Act, even if the spouse is permanently disabled, consistent with the Fifth Amendment’s equal protection component.
2. Whether limiting the marriage exception to marriages to other Social Security beneficiaries is an irrational classification.

## Decision

- The Supreme Court unanimously reversed the district court.
- The Court held that the challenged provisions do not violate the Fifth Amendment.
- The Court applied deferential rational-basis review to this social welfare classification.
- The Court upheld both (a) the general rule terminating benefits upon marriage and (b) the narrower exception for marriages to other beneficiaries.

## Legal Principles

- Social welfare classifications challenged under the Fifth Amendment’s equal protection component are generally reviewed for a rational relationship to legitimate governmental purposes.
- Congress may use marital status as a proxy for changes in dependency and may rely on general assumptions rather than individualized determinations.
- Legislatures may address perceived hardship “one step at a time” and need not extend an exception to every arguably similar case to satisfy rational-basis review.
- Administrative feasibility and avoiding individualized need or dependency inquiries are legitimate considerations supporting bright-line eligibility rules.

## Conclusion

The Court sustained Congress’s rule terminating a disabled dependent child’s Social Security benefits upon marriage to a nonbeneficiary spouse and upheld the limited exception for marriages to other beneficiaries, concluding the line-drawing was rational and administrable under the Fifth Amendment.


Califano v. Jobst, 434 U.S. 47 (1977)