## Facts

- Prior federal law paid spousal Social Security benefits to wives and widows without a dependency showing, but required husbands and widowers to prove they depended on their wives for at least one-half of their support.
- After the Court invalidated that dependency requirement for widowers, Congress amended the Social Security Act in 1977.
- The amendments (1) repealed the dependency requirement for husbands and widowers and (2) added a “pension offset” that generally reduced spousal benefits by the amount of certain federal or state government pensions.
- Congress also created a limited exception from the offset for spouses who (a) were eligible for pension benefits before a specified date and (b) would have qualified for unreduced spousal benefits under the statute as it was administered in January 1977; this exception largely benefited women.
- Congress included a severability clause providing that if the exception were held invalid, the offset would remain in force and the exception would not be extended to additional people.
- Robert H. Mathews, a retired U.S. Postal Service employee, applied for husband’s benefits on his wife’s earnings record; the agency found him eligible but fully offset his spousal benefit due to his government pension.
- Mathews brought a class action alleging the sex-based exception violated the Fifth Amendment and that the severability clause was unconstitutional; a three-judge district court agreed and invalidated both provisions.

## Issues

1. Whether Mathews had Article III standing to challenge the sex-based exception when the severability clause prevented extension of the exception to him, so success would not increase his benefits.
2. Whether the sex-based exception to the pension-offset rule violated the equal-protection component of the Fifth Amendment’s Due Process Clause.

## Decision

- The Court held Mathews had standing because being subjected to a facially discriminatory classification constitutes a cognizable injury—denial of equal treatment—even if the likely remedy would not yield additional payments to him.
- Applying intermediate scrutiny, the Court upheld the sex-based exception as serving important governmental objectives and being substantially related to those objectives.
- The Court accepted Congress’s objectives of protecting reliance interests of people who had planned retirement under prior law and preventing undue fiscal impact on the Social Security trust fund.
- The Court emphasized the exception’s narrow, time-limited “grandfathering” design tied to specified eligibility and retirement-related dates.
- The Court upheld the severability clause as a valid statement of legislative intent that any invalidity of the exception would not expand benefits and would leave the offset intact.
- The Court reversed the district court and sustained the statutory scheme.

## Legal Principles

- Standing in an equal-protection challenge may rest on the injury of unequal treatment created by a discriminatory legal barrier, not solely on loss (or prospective gain) of money.
- Federal sex-based classifications are reviewed under intermediate scrutiny: they must serve important governmental objectives and be substantially related to achieving those objectives.
- A narrowly drawn, transitional grandfather clause designed to protect reliance interests and limit fiscal exposure can satisfy intermediate scrutiny even if it operates in a sex-skewed manner.
- Congress may prescribe remedial consequences through a severability clause, including directing that an invalid exception be withdrawn rather than extended.

## Conclusion

The Court held that a plaintiff may challenge a facially discriminatory benefits exception despite a severability clause that forecloses increased benefits, and it sustained Congress’s narrow, transitional exception to a Social Security pension-offset rule as consistent with the Fifth Amendment.


Heckler v. Mathews, 465 U.S. 728 (1984)