Califano v. Goldfarb

Califano v. Goldfarb, 430 U.S. 199 (1977), was a decision by the United States Supreme Court, which held that the different treatment of men and women mandated by 42 U.S.C. § 402(f)(1)(D) constituted invidious discrimination against female wage earners by affording them less protection for their surviving spouses than is provided to male employees, and therefore violated the Due Process Clause of the Fifth Amendment to the United States Constitution.

Background

Leon Goldfarb, a widower in the state of New York, applied for survivor's benefits under the Social Security Act. Goldfarb's late wife Hannah paid Social Security taxes for 25 years, yet his application was denied. In order to be eligible for benefits under 42 U.S.C § 402, he must have been receiving half his support from his wife at her time of death. 42 U.S.C Section 402 did not impose this requirement on widows. Goldfarb challenged the statute under the Due Process Clause of the Fifth Amendment in the United States District Court for the Eastern District of New York. The District Court ruled that the statute was unconstitutional. The Government appealed to the Supreme Court

Question Before the Court

Do gender-specific requirements for benefits of the Social Security Act violate the Due Process Clause of the Fifth Amendment?

Decision of the Court

In a 5-4 decision, the Supreme Court upheld the decision of the District Court ruling that gender specific requirements for Social Security benefits unconstitutional. Citing an "indistinguishable" situation in Weinberger v. Wiesenfeld, Justice Brennan wrote the decision for the court. He noted that in Weinberger, a "indistinguishable" statutes was deemed unconstitutional. With this, and several other gender-equality cases, the court rejected the "archaic and overbroad" generalizations that a wife is more likely to be dependent on her husband than a husband on his wife." Justice Stevens wrote in concurrence with the majority, and Justice Rehnquist wrote in dissent.^[1][2]

See also

• Gender equality
• List of gender equality lawsuits
• List of United States Supreme Court cases, volume 430
• Weinberger v. Wiesenfeld (1975)

References

Further reading

• Douglas, D. M. (1978). "Social Security: Sex Discrimination and Equal Protection". Baylor Law Review 30: 199. ISSN 0005-7274. 
• Lens, Vicki (2003). "Reading between the Lines: Analyzing the Supreme Court's Views on Gender Discrimination in Employment, 1971–1982". Social Service Review 77 (1): 25–50. doi:10.1086/345703.