Carolyn Aiello experienced disability as a result of complications during her pregnancy. She was ineligible for benefits from California's Disability Fund under Section 2626 of California's Unemployment Insurance Code. Section 2626 denied benefits to women whose disabilities resulted from pregnancy. Aiello and other disabled women who were denied benefits under Section 2626 challenged the statute as a violation of the Equal Protection Clause of the Fourteenth Amendment. The United States District Court for the Northern District of California held the statute unconstitutional. The state appealed to the Supreme Court.
Did Section 2626 of California's Unemployment Insurance Code violate the Equal Protection Clause of the Fourteenth Amendment?
No. In a 6-3 decision, the Court reversed the District Court and upheld the statute. In an opinion authored by Justice Potter Stewart, the Court accepted California's interest in keeping the Disability Fund program solvent and maintaining the low contribution rate from program members. Insuring disability resulting from pregnancy complications would be "extraordinarily expensive" and make the program "impossible to maintain." As in Dandridge v. Williams, California was not obligated by the Equal Protection Clause to "choose between attacking every aspect of a problem or not attacking the problem at all." Therefore, California could constitutionally choose which disabilities to insure through the Disability Fund in order to maintain the solvency and contribution level of the program.
Decisions
Decision: 6 votes for Geduldig, 3 vote(s) against Legal provision: Equal Protection
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Full Opinion by Justice Potter Stewart
