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
- 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.
- 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.