Facts
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Ruth Wengler, an employee of Dicus Prescription Drugs, Inc., died in a work-related accident in her employer’s parking lot on February 11, 1977.
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Her husband, Paul J. Wengler, sought workers’ compensation death benefits under Mo. Rev. Stat. § 287.240.
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The statute treated surviving spouses differently by sex:
- A widow was automatically entitled to death benefits upon her husband’s work-related death, with dependency conclusively presumed.
- A widower could receive benefits only if he was mentally or physically incapacitated from wage earning or proved actual dependence on his wife’s earnings.
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As applied, the law required Wengler to prove incapacity or dependency to receive benefits, while a similarly situated widow would receive benefits without any showing of dependency.
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The Supreme Court of Missouri upheld the statute against an Equal Protection Clause challenge.
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Wengler appealed, arguing the sex-based classification unconstitutionally discriminated in allocating death benefits.
Issues
- Whether a workers’ compensation statute that grants automatic death benefits to widows but requires widowers to prove incapacity or actual dependence violates the Equal Protection Clause of the Fourteenth Amendment.
- Whether asserted administrative efficiency and generalizations about marital dependency qualify as important governmental objectives substantially served by the statute’s sex-based presumption.
Decision
- The Supreme Court reversed the judgment upholding the statute and remanded.
- The Court held that the Missouri scheme imposed unconstitutional gender-based discrimination by denying widowers benefits unless they proved incapacity or dependence while granting widows benefits without proof.
- Applying heightened scrutiny for sex classifications, the Court concluded the State’s justifications did not sufficiently support using gender as a proxy for dependency.
- The Court emphasized the statute discriminated in both directions: it burdened widowers seeking benefits and provided less protection for spouses of deceased female wage earners than for spouses of deceased male wage earners.
- Justice White wrote the Court’s opinion; Justice Stevens concurred in the judgment; Justice Rehnquist dissented.
Legal Principles
- Sex-based classifications are subject to intermediate scrutiny: they must serve important governmental objectives, and the discriminatory means must be substantially related to achieving those objectives.
- Administrative convenience can be a legitimate governmental interest, but it cannot justify sex-based presumptions grounded in unsupported generalizations about the economic roles of men and women.
- A statutory presumption that automatically awards benefits to one sex while requiring the other to prove dependency is constitutionally suspect when it is both overinclusive (awarding benefits without actual dependency) and underinclusive (withholding benefits from actual dependents absent proof requirements tied to sex).
- Equal protection analysis focuses on whether the classification’s fit is substantial; using gender as a substitute for individualized dependency determinations generally fails when the State offers only unsubstantiated assumptions.
Conclusion
The Court invalidated Missouri’s workers’ compensation provision that presumed widows’ dependency while requiring widowers to prove incapacity or dependency, holding the sex-based distinction failed intermediate scrutiny under the Equal Protection Clause and could not be justified by administrative efficiency or generalized beliefs about marital dependency.