Geduldig v. Aiello

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 denied benefits 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 and delivery, did not benefit from the amendment of the fund's requirements. The new regulations, contained in Section 2626.2, provided that:

Benefits relating to pregnancy shall be paid under this part only in accordance with 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.