Appellant
Dwight Geduldig, director of the California Department of Human Resources Development
Appellees
Carolyn Aiello, Augustina Armendariz, Elizabeth Johnson, Jacqueline Jaramillo
Appellant's Claim
That the district court erred when it ruled that California was required to pay disability benefits to private employees temporarily disabled by their pregnancies.
Chief Lawyer for Appellant
Joanne Condas
Chief Lawyer for Appellees
Wendy W. Williams
Justices for the Court
William J. Brennan, Jr., Warren E. Burger, William H. Rehnquist, Potter Stewart (writing for the Court), Byron R. White
Justices Dissenting
Harry A. Blackmun, William O. Douglas, Thurgood Marshall
Place
Washington, D.C.
Date of Decision
17 June 1974
Significance
This decision, excluding "normal pregnancy" from medical coverage, left womenwithout pregnancy problems in an intolerable financial bind. In 1978,Congress finally passed an act to cover problem-free pregnancies and deliveries for women who were otherwise covered for medical disabilities.
In the 1940s, California created an Unemployment Compensation Disability Fundto provide benefits to workers temporarily disabled by injuries or illnessesnot covered by workers' compensation. California employees contributed one percent of their salaries to the fund, up to an annual maximum of 85 dollars.In the 1970s, four women who had contributed the required percentages of their salaries to the fund, sued when they found that the fund excluded pregnancy-related disabilities from coverage.
Four Women, Different Pregnancies
Three of the women had a wide range of pregnancy-related disabilities: Carolyn Aiello suffered an ectopic pregnancy that required surgical termination; Elizabeth Johnson endured a tubal pregnancy, also necessitating surgical termination; and Augustina Armendariz miscarried. Jacqueline Jaramillo, however, had a normal pregnancy and delivery. All were excluded according to Section 2626 of the Unemployment Insurance Code, which read:
A three-judge panel of the federal district court ruled that the fund's pregnancy exclusion violated the Fourteenth Amendment of the U.S. Constitution. Dwight Geduldig, the director of California's Department of Human Resources Development, appealed to the U.S. Supreme Court, which agreed to hear the case.
Another Court Heard
Ten days before the district court ruled in Geduldig, the California Court of Appeals ruled in a case brought by another woman who had been deniedbenefits following an ectopic pregnancy. The court of appeals ruled in this case, Rentzer v. Unemployment Insurance Appeals Board (1973), that Section 2626 did not prohibit women from receiving benefits if they suffered medical complications of their pregnancies. The regulations were subsequently rewritten to exclude only "maternity benefits" for normal pregnancies and deliveries, and so Aiello, Armendariz, and Johnson--who had suffered ectopic and tubal pregnancies and a miscarriage, respectively--had their claims approved.
Jaramillo, whose disability claim was denied following a normal pregnancy anddelivery, did not benefit from the amendment of the fund's requirements. Thenew regulations, contained in Section 2626.2, provided that:
On 26 March 1974, the attorneys for Geduldig and Jaramillo presented oral arguments before the Supreme Court. Jaramillo's attorney, Wendy W. Williams, remarked that the continued exclusion of pregnancy-related disability claims arising from normal pregnancy and delivery violated the Fourteenth Amendment. Geduldig's attorney, Joanne Condas, insisted that the exclusion served the important governmental objectives of making the insurance program both self-supporting and affordable to all of the state's employees.
Is Normal Pregnancy a Disability?
In his 17 June 1974, opinion for the majority of the Court, Justice Stewart wrote that the Court had evaluated a number of "variables," including "the benefit level deemed appropriate to compensate employee disability, the risks selected to be insured . . . and the contribution rate chosen to maintain the solvency of the program and at the same time to permit low-income employees toparticipate . . . " Stewart said the Court found that the "essential issue in this case is whether the Equal Protection Clause requires such policies tobe sacrificed or compromised in order to finance the payment of benefits to those whose disability is attributable to normal pregnancy and delivery."
The Court found that California, in designing its program, had addressed itslegitimate governmental interests without engaging in "invidious discrimination under the Equal Protection Clause." Noting that "there is nothing in the Constitution . . . that requires the State to subordinate or compromise its legitimate interests solely to create a more comprehensive social program thanit already has," Stewart wrote that the plan included "no risk from which menare protected and women are not. Likewise, there is no risk from which womenare protected and men are not." The court reversed the judgment of the district court, and permitted California to retain the exclusion for disability claims arising from normal pregnancy and delivery.
Creating a Double Standard
Justice Blackmun wrote a spirited dissent, joined by Justices Douglas and Marshall:
Congress to the Rescue
In 1976, the female employees of General Electric sued, claiming that the pregnancy exclusions contained in their company's insurance plan violated TitleVII of the Civil Rights Act of 1964. Relying on its decision in Geduldig, the Supreme Court ruled that private employers did not violate federal law when they chose to deny medical disability payments to workers with maternity-related absences.
In 1978, Congress amended Title VII to include the Pregnancy Discrimination Act. The act specifically provided that "women affected by pregnancy, childbirth, or related medical conditions shall be treated the same for all employment-related purposes . . . as other persons not so affected but similar in their ability or inability to work . . . "
Related Cases
Workers' Compensation
Worker's compensation provides lost wages and funds for medical costs to workers injured on the job. All 50 states have workers compensation laws. Injuries covered are commonly associated with specific accidents on the job such asfalling on stairs or off a ladder. Occupational-related diseases, such as miner's "black lung" disease, are also covered. The injury must arise from employment. That is, a causal connection between work and the injury must be demonstrated. Also, the injury must occur in the course of employment, during working hours, at a work location, and while performing work duties. Employers must purchase worker's compensation insurance for their employees or provide aself-insured program. Employers often pass along the cost of insurance to their customers.
Worker's compensation laws are no-fault laws meaning benefits are paid without regard to the fault or negligence of either the employer or employee. Benefits include medical and indemnity (compensation) payments. Hospital and othermedical payments are made with the goal of returning the employee to the job. Indemnity benefits compensate a worker for loss of income. Should the injury result in death, the worker's spouse and any children up to age 18 may receive payments.
Sources
Hardy, Benjamin A. Jr., Jack B. Hood, and Harold S. Lewis, Jr. Workers' Compensation and Employee Protection Laws in a Nutshell. Minneapolis/St. Paul, MN: West Publishing, 1990.
Dwight Geduldig, director of the California Department of Human Resources Development
Appellees
Carolyn Aiello, Augustina Armendariz, Elizabeth Johnson, Jacqueline Jaramillo
Appellant's Claim
That the district court erred when it ruled that California was required to pay disability benefits to private employees temporarily disabled by their pregnancies.
Chief Lawyer for Appellant
Joanne Condas
Chief Lawyer for Appellees
Wendy W. Williams
Justices for the Court
William J. Brennan, Jr., Warren E. Burger, William H. Rehnquist, Potter Stewart (writing for the Court), Byron R. White
Justices Dissenting
Harry A. Blackmun, William O. Douglas, Thurgood Marshall
Place
Washington, D.C.
Date of Decision
17 June 1974
Significance
This decision, excluding "normal pregnancy" from medical coverage, left womenwithout pregnancy problems in an intolerable financial bind. In 1978,Congress finally passed an act to cover problem-free pregnancies and deliveries for women who were otherwise covered for medical disabilities.
In the 1940s, California created an Unemployment Compensation Disability Fundto provide benefits to workers temporarily disabled by injuries or illnessesnot covered by workers' compensation. California employees contributed one percent of their salaries to the fund, up to an annual maximum of 85 dollars.In the 1970s, four women who had contributed the required percentages of their salaries to the fund, sued when they found that the fund excluded pregnancy-related disabilities from coverage.
Four Women, Different Pregnancies
Three of the women had a wide range of pregnancy-related disabilities: Carolyn Aiello suffered an ectopic pregnancy that required surgical termination; Elizabeth Johnson endured a tubal pregnancy, also necessitating surgical termination; and Augustina Armendariz miscarried. Jacqueline Jaramillo, however, had a normal pregnancy and delivery. All were excluded according to Section 2626 of the Unemployment Insurance Code, which read:
"Disability" or"disabled" includes both mental or physical illness and mental or physical injury. An individual shall be deemed disabled in any day in which, because ofhis [or her] physical or mental condition, he [she] is unable to perform his[her] regular or customary work. In no case shall the term "disability" or "disabled" include any injury or illness caused by or arising in connection with pregnancy up to the termination of such pregnancy and for a period of 28 days thereafter.
A three-judge panel of the federal district court ruled that the fund's pregnancy exclusion violated the Fourteenth Amendment of the U.S. Constitution. Dwight Geduldig, the director of California's Department of Human Resources Development, appealed to the U.S. Supreme Court, which agreed to hear the case.
Another Court Heard
Ten days before the district court ruled in Geduldig, the California Court of Appeals ruled in a case brought by another woman who had been deniedbenefits following an ectopic pregnancy. The court of appeals ruled in this case, Rentzer v. Unemployment Insurance Appeals Board (1973), that Section 2626 did not prohibit women from receiving benefits if they suffered medical complications of their pregnancies. The regulations were subsequently rewritten to exclude only "maternity benefits" for normal pregnancies and deliveries, and so Aiello, Armendariz, and Johnson--who had suffered ectopic and tubal pregnancies and a miscarriage, respectively--had their claims approved.
Jaramillo, whose disability claim was denied following a normal pregnancy anddelivery, did not benefit from the amendment of the fund's requirements. Thenew regulations, contained in Section 2626.2, provided that:
Benefits relating to pregnancy shall be paid under this part only in accordancewith the following: (a) Disability benefits shall be paid upon a doctor's certification that the claimant is disabled because of an abnormal and involuntary complication of pregnancy, including but not limited to: puerperal infection, eclampsia, caesarian section delivery, ectopic pregnancy, and toxemia. (b) Disability benefits shall be paid upon a doctor's certification that a condition possibly arising out of pregnancy would disable the claimant without regard to the pregnancy, including but not limited to: anemia, diabetes, embolism, heart disease, hypertension, phlebitis, phlebothrombosis, pyelonephritis,thrombophlebitis, vaginitis, varicse veins, and venous thrombosis.
On 26 March 1974, the attorneys for Geduldig and Jaramillo presented oral arguments before the Supreme Court. Jaramillo's attorney, Wendy W. Williams, remarked that the continued exclusion of pregnancy-related disability claims arising from normal pregnancy and delivery violated the Fourteenth Amendment. Geduldig's attorney, Joanne Condas, insisted that the exclusion served the important governmental objectives of making the insurance program both self-supporting and affordable to all of the state's employees.
Is Normal Pregnancy a Disability?
In his 17 June 1974, opinion for the majority of the Court, Justice Stewart wrote that the Court had evaluated a number of "variables," including "the benefit level deemed appropriate to compensate employee disability, the risks selected to be insured . . . and the contribution rate chosen to maintain the solvency of the program and at the same time to permit low-income employees toparticipate . . . " Stewart said the Court found that the "essential issue in this case is whether the Equal Protection Clause requires such policies tobe sacrificed or compromised in order to finance the payment of benefits to those whose disability is attributable to normal pregnancy and delivery."
The Court found that California, in designing its program, had addressed itslegitimate governmental interests without engaging in "invidious discrimination under the Equal Protection Clause." Noting that "there is nothing in the Constitution . . . that requires the State to subordinate or compromise its legitimate interests solely to create a more comprehensive social program thanit already has," Stewart wrote that the plan included "no risk from which menare protected and women are not. Likewise, there is no risk from which womenare protected and men are not." The court reversed the judgment of the district court, and permitted California to retain the exclusion for disability claims arising from normal pregnancy and delivery.
Creating a Double Standard
Justice Blackmun wrote a spirited dissent, joined by Justices Douglas and Marshall:
The economic effects caused by pregnancy-related disabilities are functionally indistinguishable from the effects caused by any other disability: wages are lost due to a physical inability to work, and medical expenses are incurred for the delivery of the child and for postpartum care. Inmy view, by singling out for less favorable treatment a gender-linked disability peculiar to women, the State has created a double standard for disability compensation: a limitation is imposed upon the disabilities for which womenworkers may recover, while men receive full compensation for all disabilities suffered, including those that affect only or primarily their sex, such asprostatectomies, circumcision, hemophilia, and gout.
Congress to the Rescue
In 1976, the female employees of General Electric sued, claiming that the pregnancy exclusions contained in their company's insurance plan violated TitleVII of the Civil Rights Act of 1964. Relying on its decision in Geduldig, the Supreme Court ruled that private employers did not violate federal law when they chose to deny medical disability payments to workers with maternity-related absences.
In 1978, Congress amended Title VII to include the Pregnancy Discrimination Act. The act specifically provided that "women affected by pregnancy, childbirth, or related medical conditions shall be treated the same for all employment-related purposes . . . as other persons not so affected but similar in their ability or inability to work . . . "
Related Cases
- Cleveland Board of Education v. LaFleur, 414 U.S. 632 (1974).
- Cohen v. Chesterfield County School Board, 414 U.S. 632 (1974).
- General Electric v. Gilbert, 429 U.S. 125 (1976).
- Nashville Gas Co. v. Satty, 434 U.S. 136 (1977).
Workers' Compensation
Worker's compensation provides lost wages and funds for medical costs to workers injured on the job. All 50 states have workers compensation laws. Injuries covered are commonly associated with specific accidents on the job such asfalling on stairs or off a ladder. Occupational-related diseases, such as miner's "black lung" disease, are also covered. The injury must arise from employment. That is, a causal connection between work and the injury must be demonstrated. Also, the injury must occur in the course of employment, during working hours, at a work location, and while performing work duties. Employers must purchase worker's compensation insurance for their employees or provide aself-insured program. Employers often pass along the cost of insurance to their customers.
Worker's compensation laws are no-fault laws meaning benefits are paid without regard to the fault or negligence of either the employer or employee. Benefits include medical and indemnity (compensation) payments. Hospital and othermedical payments are made with the goal of returning the employee to the job. Indemnity benefits compensate a worker for loss of income. Should the injury result in death, the worker's spouse and any children up to age 18 may receive payments.
Sources
Hardy, Benjamin A. Jr., Jack B. Hood, and Harold S. Lewis, Jr. Workers' Compensation and Employee Protection Laws in a Nutshell. Minneapolis/St. Paul, MN: West Publishing, 1990.
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