Congress responded to the Court's decision in Califano v. Goldfarb (1977), which invalidated a gender-based dependency requirement in the allocation of Social Security payments, and to the necessity of preventing bankruptcy in the Social Security fund. It enacted amendments in 1977 to the Social Security Act. The 1977 amendments included a "pension offset" provision which reduced spousal benefits by the amount of certain federal and state pension funds that a Social Security applicant received. However, Congress exempted from this provision spouses who were eligible to receive pension benefits prior to December 1982 and who would have qualified for unreduced spousal benefits prior to the Court's Califano decision.
Did the resurrection of pre-California law which allowed some gender-based classification in Social Security allocations violate the Due Process Clause of the Fifth Amendment?
The unanimous Court upheld the law. Justice Brennan granted that the 1977 amendments temporarily revived gender-based eligibility requirements, but maintained that they served a legitimate government interest, namely, they protected individuals who had planned for their retirements relying on the law as it stood before the Court's Califano decision. The resurrected eligibility criteria were narrowly drawn, applying to those individuals who were eligible for spousal benefits prior to 1977 who retired by 1982. Since many individuals who are planning for retirement rely on the law in making investment and spending decisions, changing the law (as Califano did) without giving some leeway to people who had already planned for the future would place an unreasonable burden on many who were close to retirement.
Decisions
Decision: 9 votes for Heckler, 0 vote(s) against Legal provision: Social Security, as amended, including Social Security Disability Benefits Reform Act, but excluding Medicare, Medicaid, Supplemental Security Income, and Aid to Families with Dependent Children
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Full Opinion by Justice William J. Brennan, Jr.
