## Facts

- Ramon Jimenez, a covered wage earner under the Social Security Act, became entitled to disability benefits in October 1963 while residing in Illinois.
- After the onset of disability, Jimenez fathered two children, Eugenio (1965) and Alicia (1968), who were illegitimate and not legitimated under state law.
- Illinois law did not permit nonlegitimated illegitimate children to inherit from their father.
- The Social Security Act treated some illegitimate children as conclusively “dependent” and eligible for child’s benefits if they could inherit under state law, were legitimated, or were the product of a ceremonial marriage with only a formal defect.
- Illegitimate children who did not meet those routes could qualify only if, before the onset of disability, the wage earner lived with the child or contributed to the child’s support (42 U.S.C. § 416(h)(3)(B)).
- Eugenio and Alicia lived with Jimenez and were supported by him, but because they were born after the onset of disability, they could not satisfy the pre-disability cohabitation or support requirement.
- Their applications for child’s insurance benefits were denied, while another child in the household born before disability was found eligible.

## Issues

1. Whether the Social Security Act’s denial of child’s disability benefits to nonlegitimated, after-born illegitimate children who cannot satisfy 42 U.S.C. § 416(h)(3)(B) violates the equal protection component of the Fifth Amendment’s Due Process Clause.
2. Whether a complete statutory bar on eligibility for that subclass of children is reasonably related to the governmental interest in preventing fraudulent or spurious claims.

## Decision

- The Supreme Court reversed the judgment upholding the statute.
- The Court held the statutory scheme, as applied to nonlegitimated, after-born illegitimate children in the appellants’ position, violated the Fifth Amendment’s equal protection guarantee.
- The Court concluded the complete bar was not reasonably related to the asserted interest in preventing spurious claims, because similarly situated risks of false claims existed for favored categories of children who received benefits without proving dependency.
- The Court rejected the view that the program’s aim was limited to replacing only pre-disability support, reasoning that the program’s central purpose was to provide support to dependents of a disabled wage earner.

## Legal Principles

- The Fifth Amendment’s Due Process Clause contains an equal protection component that limits federal statutory classifications.
- Classifications based on illegitimacy must, at minimum, bear a rational relationship to a legitimate governmental objective and may not arbitrarily penalize children for the circumstances of their birth.
- Fraud prevention is a legitimate objective, but Congress may not pursue it through an absolute exclusion that denies an entire subclass any opportunity to establish actual dependency while granting benefits to other groups without comparable proof.
- A benefits scheme is constitutionally suspect when it is both overinclusive (granting benefits without proof of actual dependency to some) and underinclusive (denying benefits to actual dependents) in a way that lacks a reasonable connection to the stated objective.

## Conclusion

The Court invalidated the Social Security Act’s categorical denial of child’s insurance benefits to nonlegitimated illegitimate children born after a wage earner’s disability when the scheme foreclosed any chance to prove actual dependency and did not reasonably advance the asserted anti-fraud justification.


Jimenez v. Weinberger, 417 U.S. 628 (1974)