## Facts

- Ruby M. Lucas and her children sought Social Security surviving child’s benefits after the death of the children’s father, a fully insured wage earner.
- The Social Security Act requires that a child be dependent on the insured at the time of death; certain categories of children are deemed dependent without individualized proof.
- Legitimate children, and children who could inherit from the insured under state law, are presumed dependent.
- Additional presumptions apply to some nonmarital children if the insured participated in a (defective) marriage ceremony with the parent, acknowledged the child in writing, was judicially determined to be the father, or was ordered to support the child.
- The Lucas children established paternity but did not qualify for any statutory presumption and, in the agency’s view, did not prove the insured was living with them or contributing to their support at the time of death.
- The agency denied benefits and affirmed the denial on administrative appeal.
- The federal district court held the statutory classifications unconstitutional under the equal protection component of the Fifth Amendment’s Due Process Clause and ordered benefits paid.
- The Secretary appealed directly to the U.S. Supreme Court.

## Issues

1. Whether a federal benefits statute that distinguishes between legitimate and illegitimate children triggers strict scrutiny.
2. Whether the Social Security Act’s presumptions of dependency, which favor legitimate children and certain categories of illegitimate children, violate the equal protection component of the Fifth Amendment as applied to other illegitimate children.

## Decision

- The Supreme Court reversed the district court and upheld the challenged provisions.
- The Court held that legitimacy-based classifications do not require strict scrutiny.
- The Court concluded that the dependency presumptions and the requirement of individualized proof for other children are constitutionally permissible because they are reasonably related to the likelihood of dependency at the insured’s death.
- The Court emphasized Congress’s authority to use administrable general rules in a large contributory insurance program to approximate dependency and control administrative burdens.

## Legal Principles

- The Fifth Amendment’s Due Process Clause includes an equal protection component applicable to federal benefit classifications.
- Classifications based on illegitimacy receive more searching review than ordinary economic regulation but are not treated as “suspect” classifications requiring strict scrutiny.
- In a national benefits program, Congress may use categorical presumptions to approximate a fact (such as dependency) when the categories bear a fair and substantial relation to the program’s objective.
- Administrative efficiency and workable administration may justify using general dependency presumptions rather than requiring individualized determinations in every case.

## Conclusion

The Court sustained the Social Security Act’s dependency presumptions, holding that Congress could treat legitimate children and certain categories of illegitimate children as presumptively dependent because those categories reasonably correlate with likely dependency and permit efficient administration, and that requiring other illegitimate children to prove actual dependency does not violate equal protection under the Fifth Amendment.


Mathews v. Lucas, 427 U.S. 495 (1976)