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Califano v. Goldfarb - Significance

social security benefits dependency

Widowers would no longer have to prove dependency on their spouses in order to receive survivor benefits from the Social Security employment taxes their spouses had paid throughout their lives.

When a person in the United States begins working, he also begins paying Social Security tax which provides protection for him and his family in the form of Social Security benefits, once he retires or dies. Prior to this case, according to the Social Security Act, when a female who has accrued these benefits dies, her spouse must prove that he was dependent on his wife for at least half of his support, in order to claim survivor benefits. A woman whose husband has died, on the contrary, does not need to prove such dependency upon her husband's income in order to receive the same benefits.

Mrs. Hannah Goldfarb worked as a secretary in the New York City public school system for almost 25 years until she died in 1968. Her husband, Leon, sought survivor's benefits but was turned down as he could not prove the needed dependency. He challenged the constitutionality of the Social Security Act's gender-distinction in the U.S. District Court for the Eastern District of New York. The three judges of the district court agreed with Goldfarb, finding that the burden of proof discriminated against female wage-earners by providing them less protection for their families than men received. Joseph Califano, U.S. Secretary of Health, Education, and Welfare at that time, appealed directly to the Supreme Court on behalf of the Social Security program.

The Court agreed with the lower court's decision, although it could not agree on an opinion among the justices. Justice Brennan was joined in his opinion by Justices White, Marshall, and Powell. It stated that the gender-based distinction violated equal protection under Due Process Clause of the Fifth Amendment since women's employment and contributions to Social Security resulted in less protection for their families than men's contributions did. Justice Stevens, in his own opinion, found that the distinction actually discriminated against men and was the "accidental by-product of a traditional way of thinking about females." This presumption rested on the fact that men were rarely dependent on their wives for half their income. Men were therefore requested to confirm this dependency. Stevens felt it unjust that men needed to prove dependency on their spouses. He continued, noting something more than an "accident" was needed to justify unequal treatment of the surviving spouses.

Justices Burger, Stewart, Blackmun, and Rehnquist disagreed that the classification was discriminatory. Rehnquist's opinion argued that it was justified on the basis of "administrative convenience" given that a widow's dependency on her husband is most often the case. Rehnquist also noted the classification was justified by referencing a previous case involving widows and property tax which relieved widows in order to improve their "characteristically depressed" condition.

As a result of this ruling, the Social Security Act needed to be amended in order to eliminate the burden of proof for widowers, providing equal protection for both female and male workers and their families who would receive benefits from Social Security.

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