et al. Heckler v. Mathews

After Robert Mathews retired from the U.S. Postal Service, he applied for Social Security spousal benefits on his wife's account. Unlike non-civil servant retirees, Mathews did not have to offset double benefits against his spouse's account; civil servants could receive full spousal benefits along with their government pensions. However, under the provisions of Social Security Act (as amended by Congress in 1977), Mathews was denied benefits because he did not depend on his wife for one-half support. After being administratively denied benefits, Mathews requested and received a hearing by an Administrative Law Judge (ALJ) who declared valid the decision to withhold benefits. Mathews pursued his claim via the Appeals Counsel of the Department of Health and Human Services (DHHS); that review also affirmed denial of benefits. As a result, the Secretary of DHHS, Margaret Heckler, issued an official decision on behalf of the DHHS to enforce the findings of the ALJ and Appeals Counsel.

Mathews continued to believe he had been unjustly denied benefits to which he was entitled and had exhausted all available administrative avenues available through the DHHS. He then filed suit on behalf of himself and the class of other nondependent men affected by Heckler's decision. In presenting his case before the U.S. District Court for the Northern District of Alabama, Mathews sought a declarative judgment ruling that the pension offset of the 1977 amended Social Security Act was unconstitutional.

The linchpin to Mathews's argument was the Supreme Court's ruling in Califano v. Goldfarb. According to the Goldfarb ruling, gender discrimination was inherent in the pension offset exemption because it violated due process for nondependent men who were similarly situated as nondependent woman who received benefits. Further, Mathews's attorney claimed the Goldfarb decision rendered the severability clause unconstitutional--it perpetuated gender discrimination against nondependent men by enforcing the offset exemption clause even though it was held violative of the U.S. Constitution.

In considering the class action claim, the district court first determined that Mathews indeed had standing to bring suit. The pension offset exemption and severability clause assumed gender-based classification; therefore, withholding benefits from the "excluded class" of nondependent men while extending benefits to the "favored class" constituted unequal treatment. Mathews's "injury" qualified him for legal redress. In examining the issues raised in the suit, the district court pointed out that discrimination could only be upheld if it served "important governmental objectives and [was] substantially related to achievement of those objectives." However, the rationale behind the exclusion exemption of the pension offset was faulty. As the Supreme Court ruled in Goldfarb, "Women would have relied upon the practices of the Social Security Administration, yet men would not have relied upon a decision of the Supreme Court." That, the district court believed, violated equal protection provided by the Due Process Clause of the Fifth Amendment.

Finally, in considering the congressional offset provision of the amended Social Security Act, the justices held that even if the person achieved success in challenging the provision's constitutionality, the outcome would still penalize litigants because the pension offset would still remain in effect. The district court viewed such an outcome as merely a means by which Congress made any challenge "fruitless." Further, since the court felt Congress had intended to serve a governmental interest in not penalizing retirees, the severability clause was "an adroit attempt to discourage the bringing of an action by destroying standing." Thus, the district court held the offset exemption and severability clause as unconstitutional and ordered the DHHS to pay benefits without consideration of dependency and without offset of benefits. After the ruling of the district court, the Secretary of DHHS directly appealed to the Supreme Court for a reversal of the decision.