Facts
- Federal law provided “wife’s insurance benefits” to certain spouses of a worker entitled to old-age or disability benefits.
- Under the challenged provision, a woman under age 62 could receive benefits based on having an entitled child in her care only “in the case of a wife,” effectively limiting that pathway to women who were currently married to the wage earner.
- Helen De Castro divorced her husband after a long marriage and cared for their disabled child, who received child’s insurance benefits.
- After her former husband became entitled to old-age benefits, De Castro applied for wife’s insurance benefits.
- The agency denied the claim because, as a divorced woman under 62, she was ineligible under the statutory classification.
- A three-judge federal district court declared the provision unconstitutional and enjoined its enforcement, concluding the distinction lacked a rational basis.
Issues
- Whether denying wife’s insurance benefits to divorced women under 62 who have an entitled child in their care, while allowing such benefits to similarly situated married women, violates the Fifth Amendment’s Due Process Clause.
Decision
- The Supreme Court reversed the district court and upheld the statute.
- The Court applied rational basis review to the federal social welfare classification.
- The Court held the different treatment of married and divorced women under 62 was rationally related to the program’s objectives and therefore constitutional.
- Justice Marshall concurred in the judgment.
Legal Principles
- Federal social welfare classifications are reviewed under a highly deferential rational basis standard and are upheld if not irrational.
- Congress may address perceived social and economic problems incrementally and may employ generalizations and line-drawing within large benefit programs.
- A marital-status classification in benefits eligibility is permissible where Congress could reasonably conclude that intact marital households face distinct economic disruption when the wage earner retires or becomes disabled.
- Divorced spouses may be treated differently based on the reasonable assumption that they typically live separate economic lives and that ongoing support obligations may be handled through state domestic-relations mechanisms rather than federal benefits keyed to the worker’s retirement or disability.
Conclusion
The Court held that the Social Security Act’s limitation of certain under-62 benefits to married women with an entitled child in their care, while deferring comparable eligibility for divorced women until age 62, was a rational legislative judgment consistent with the Fifth Amendment.