et al. Heckler v. Mathews

In considering the petitioner's claim, the U.S. Supreme Court too, needed to establish the validity of Mathews's (now the respondent) standing to bring suit. The Court considered both petitioner's and respondent's arguments. The petitioner maintained that benefits were awarded according to classifications (that of retirees) and were not tied to a monetary award of benefits; hence, there was no differentiation by gender. By agreeing with this point, the justices held that the respondent (Mathews) could reasonably qualify as representative of a class lawsuit. But, to further ascertain the respondent's validity, the Court needed to apply "case or controversy" criteria established by Gladstone, Realtors v. Village of Bellwood (1979) and Simon v. Eastern Kentucky Welfare Rights Organization (1976). By not awarding the same benefits to nondependent men and women, the DHHS appeared to be stigmatizing a "disfavored group" in a manner that could cause "serious noneconomic injuries." Hence, according to the legal rubric of Gladstone, the respondent had satisfied the need to show injury due to the conduct of DHHS. Further, since the severability clause would result in withdrawal of benefits from which the respondent could gain relief "by a favorable decision," and since the respondent invoked the right to equitable treatment in which "the appropriate remedy is a mandate of equal treatment," the respondent qualified for standing in accordance with the Simon decision.

In considering the rationale of the lower district court, the justices agreed that the pension offset applied only to men who could show that half their support derived from their spouse's income (ruled unconstitutionally gender-biased according to the Goldfarb decision). However, the Court reasoned that "favoring constructions of statutes to avoid constitutional questions" did not "license a court to usurp the policymaking and legislative functions of the duly elected representatives." Hence, after they carefully examined the language of the (1977) amended Social Security Act, the justices held that Congress specifically intended to grant a five-year extension only to address the need of retirees who made plans according to pre-Goldfarb legislation. Thus, the Supreme Court reasoned that, "the congressional aim of preventing a fiscal drain on the Social Security trust fund" was circumvented by the district court's requirement that benefits be extended to all retirees.

Ultimately, in a unanimous ruling, the Supreme Court re-confirmed its position regarding discrimination by rendering a decision that was historically and legally consistent with previous rulings. While the pension offset exception did temporarily restore gender-based classifications when awarding retiree benefits, discrimination was "directly and substantially" linked to an important government objective. Congress' only intent was to protect "individuals who planned their retirements in reasonable reliance on the law in effect" prior to the Goldfarb decision. Thus, the exception discriminated "not according to archaic generalizations" about gender roles, but on whether people planned their retirement expecting to receive Social Security benefits according to the law. Accordingly, the Supreme Court reversed the decision of the lower court and, tacitly, upheld the constitutionality of Social Security Act as amended by Congress in December of 1977.