Geduldig v. Aiello
417 U.S. 484 (1974)

Annotate this Case
  • Syllabus  | 
  • Case

U.S. Supreme Court

Geduldig v. Aiello, 417 U.S. 484 (1974)

Geduldig v. Aiello

No. 73-640

Argued March 26, 1974

Decided June 17, 1974

417 U.S. 484

Syllabus

California has a disability insurance system for private employees temporarily disabled from working by an injury or illness not covered by workmen's compensation, under which an employee contributes to an Unemployment Compensation Disability Fund one percent of his salary up to an annual maximum of $85. A disability lasting less than eight days is not compensable, except when the employee is hospitalized. Benefits are not payable for a single disability exceeding 26 weeks. A disability resulting from an individual's court commitment as a dipsomaniac, drug addict, or sexual psychopath is not compensable, nor are certain disabilities attributable to pregnancy. Appellees, four women otherwise qualified under the program who have suffered employment disability because of pregnancies, only one of which was normal, challenged the pregnancy exclusion. A three-judge District Court upheld their contention that the exclusion violated the Equal Protection Clause. The court denied a motion to reconsider based on a state appellate court ruling, in which appellant who administers the program has acquiesced, confining the exclusion to only normal pregnancies. The California program, in terms of the level of benefits and risks insured, is structured to maintain the solvency of the Disability Fund at a one-percent annual level of contribution. The District Court acknowledged that coverage of disabilities resulting from normal pregnancies would entail substantial additional expense. But it concluded that this increased cost could be accommodated through adjustments in the rate of employee contribution, the maximum benefits payable, "and the other variables affecting the solvency of the program."

Held:

1. The appellate ruling and administrative guidelines excluding only normal pregnancies have mooted the case as to the three appellees who had abnormal pregnancies and whose claims have now been paid. Pp. 417 U. S. 491-492.

Page 417 U. S. 485

2. California's decision not to insure under its program the risk of disability resulting from normal pregnancy does not constitute an invidious discrimination violative of the Equal Protection Clause. The program does not discriminate with respect to the persons or groups eligible for its protection, and there is no evidence that it discriminates against any definable group or class in terms of the aggregate risk protection derived from the program. The sole contention is the asserted underinclusiveness of the program's coverage as a result of the exclusion of disabilities resulting from normal pregnancy. The State is not required by the Equal Protection Clause to sacrifice the self-supporting nature of the program, reduce the benefits payable for covered disabilities, or increase the maximum employee contribution rate just to provide protection against another risk of disability, such as normal pregnancy.

"[T]he Equal Protection Clause does not require that a State must choose between attacking every aspect of a problem or not attacking the problem at all."

Dandridge v. Williams, 397 U. S. 471, 397 U. S. 486-487. Pp. 417 U. S. 492-497.

359 F.Supp. 792, reversed.

STEWART, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, BLACKMUN, POWELL, and REHNQUIST, JJ., joined. BRENNAN, J., filed a dissenting opinion, in which DOUGLAS and MARSHALL, JJ., joined, post, p. 417 U. S. 497.

Page 417 U. S. 486

Primary Holding
It is permissible under the Fourteenth Amendment for a state disability insurance system to exclude coverage for pregnancy-related disabilities.
Facts
The entirely self-supporting disability insurance system in California paid benefits to people in private employment who were temporarily unable to work but would not be eligible for workers' compensation benefits. Each employee contributed one percent of his or her income to the fund in exchange for being insured against the risk of disability resulting from many types of mental and physical injuries and illnesses. However, the program defined "disability" in a way that excluded certain pregnancy-related disabilities. Women suffering from these disabilities, who otherwise would have been eligible to receive benefits under the program, argued that it violated the Equal Protection Clause. The lower court agreed that the program engaged in gender discrimination.

Opinions

Majority

  • Potter Stewart (Author)
  • Warren Earl Burger
  • Byron Raymond White
  • Harry Andrew Blackmun
  • Lewis Franklin Powell, Jr.
  • William Hubbs Rehnquist

The state may choose not to insure certain risks as long as it is does not facially discriminate against certain persons or groups who otherwise would be eligible for coverage. This system is similar to an ordinary insurance program, which does not have to cover every disabling condition. If the program covered the pregnancy-related disabilities, its costs would rise to the point where it no longer could be supported on employee contributions alone. The appropriate standard of review with respect to this type of program is rational basis. The state has made a reasonable decision to create an insurance system that does not require state subsidies and keeps contributions relatively low while paying out a meaningful amount of benefits.

States are not constitutionally required to have more comprehensive social welfare programs than they currently do. There is no illegitimate or malignant motive behind the state's exclusion of pregnancy-related disabilities. The exclusion is based on pregnancy rather than sex, which makes it less likely to involve discrimination.

Dissent

  • William Joseph Brennan, Jr. (Author)
  • William Orville Douglas
  • Thurgood Marshall

Pregnancy-related disabilities are in fact specifically tied to gender because only women suffer from them. They have a comparable economic impact to other disabilities covered by the program because they require similar types of treatments and procedures. The current system imposes a double standard for disability benefits. While men receive full coverage for male-specific disabilities, women do not receive full coverage for female-specific disabilities.

Case Commentary

Whether a reader agrees with the majority or dissent depends on whether the legislation is viewed as naturally underinclusive, which is acceptable, or whether it is viewed as disproportionately excluding a certain gender, which is not permissible.

Disclaimer: Justia Annotations is a forum for attorneys to summarize, comment on, and analyze case law published on our site. Justia makes no guarantees or warranties that the annotations are accurate or reflect the current state of law, and no annotation is intended to be, nor should it be construed as, legal advice. Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship.

Disclaimer: Official Supreme Court case law is only found in the print version of the United States Reports. Justia case law is provided for general informational purposes only, and may not reflect current legal developments, verdicts or settlements. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or information linked to from this site. Please check official sources.