Heckler v. Mathews
Annotate this Case
465 U.S. 728 (1984)
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U.S. Supreme Court
Heckler v. Mathews, 465 U.S. 728 (1984)
Heckler v. Mathews
Argued December 5, 1983
Decided March 5, 1984
465 U.S. 728
Prior to 1977, spousal benefits under the Social Security Act (Act) were payable only to husbands or widowers who could demonstrate dependency on their wives for one-half of their support, whereas wives and widows were entitled to benefits without any such showing of dependency on their husbands. In Califano v. Goldfarb, 430 U. S. 199, this Court affirmed a District Court judgment holding that the gender-based dependency requirement for widowers violated the equal protection component of the Due Process Clause of the Fifth Amendment. Thereafter, while repealing the dependency requirement for widowers and husbands, Congress, in order to avoid a fiscal drain on the Social Security trust fund, enacted a "pension offset" provision that generally requires the reduction of spousal benefits by the amount of Federal or State Government pensions received by the Social Security applicant. However, in order to protect the interests of those individuals who had retired or were about to retire and who had planned their retirements in reliance on their entitlement, under pre-1977 law, to spousal benefits unreduced by government pension benefits, Congress exempted from the pension offset requirement those spouses who were eligible to receive pension benefits prior to December, 1982, and who would have qualified for unreduced spousal benefits under the Act as administered in January, 1977. Congress also included a severability clause which, in substance, provides that, if the exception to the pension offset requirement is held invalid, that requirement would not be affected, and the application of the exception would not be broadened to include persons not included within it. Appellee husband (hereafter appellee), after retiring from the United States Postal Service, applied for husband's benefits under the Act on account of his wife, who had retired earlier and was fully insured under the Act. It was determined administratively that, although appellee was entitled to spousal benefits, they were entirely offset by his Postal Service pension pursuant to the pension offset provision of the Act. Appellee and his wife then brought a class action in Federal District Court, alleging that application of the pension offset provision to him and other nondependent men, but not to similarly situated nondependent women, violated the Due Process Clause of the Fifth Amendment, and that the severability clause was also unconstitutional.
The District Court held both the pension offset provision and the severability clause unconstitutional, concluding that the latter would, if valid, deprive appellee of standing to bring the action by preventing him from receiving any more spousal benefits if he prevails than he is now allowed.
1. Appellee has standing to prosecute this action. Because the right he asserts is the right to receive benefits according to classifications that do not without sufficient justification differentiate among covered applicants solely on the basis of sex, and not a substantive right to any particular amount of benefits, appellee's standing does not depend on his ability to obtain increased Social Security payments. The right to equal treatment guaranteed by the Constitution is not coextensive with any substantive rights to the benefits denied the party discriminated against. Rather, discrimination itself, by perpetuating "archaic and stereotypic notions" or by stigmatizing members of the disfavored group as "innately inferior," and therefore less worthy participants in the political community, can cause serious noneconomic injuries to those persons who are denied equal treatment solely because of their membership in a disfavored group. Because the severability clause would forbid only the extension of benefits to the excluded class and not the withdrawal of benefits from the favored class, the injury caused by the unequal treatment allegedly suffered by appellee may be redressed. Pp. 465 U. S. 737-740.
2. The pension offset exception applies to otherwise eligible men only when they can show dependency on their wives for one-half of their support. The language and history of the exception plainly demonstrate that Congress intended to resurrect, for a 5-year grace period, the gender-based dependency test of pre-Goldfarb law so as to afford protection to those who anticipated receiving spousal benefits prior to Goldfarb without providing it also to those who would qualify only as a result of the Goldfarb decision. To interpret the exception, as appellee urges, so that it does not incorporate a gender-based classification of the kind invalidated in Goldfarb, but instead exempts from the offset requirement both men and women, without regard to dependency, would defeat Congress' intention and, by rendering the offset requirement applicable to only a few applicants, frustrate the congressional aim of preventing a fiscal drain on the Social Security trust fund. Pp. 465 U. S. 741-744.
3. The gender-based classification of the pension offset exception is constitutional. Pp. 465 U. S. 744-751.
(a) Although temporarily reviving the gender-based classification invalidated in Goldfarb, the offset exception is directly and substantially related to the important governmental objective of protecting individuals who planned their retirements in reasonable reliance on the law in effect prior to that decision under which they could receive spousal benefits
unreduced by the amount of government pensions to which they were also entitled. This objective provides an exceedingly persuasive justification for the gender-based classification incorporated in the offset exception. Pp. 465 U. S. 745-748.
(b) And the means employed by the statute is substantially related to the achievement of that objective. By reviving for a 5-year period the eligibility criteria in effect in January, 1977, the offset exception is narrowly tailored to protect only those persons who made retirement plans prior to the changes in the law that occurred after that date. Such persons, men as well as women, may receive spousal benefits unreduced by their government pensions while those persons, men as well as women, who first became eligible for benefits after January, 1977, may not. The exception distinguishes Social Security applicants, not according to archaic generalizations about the roles and abilities of men and women, but rather according to whether they planned their retirements with the expectation, created by the law in effect in January, 1977, that they would receive full spousal benefits and a government pension. Pp. 465 U. S. 748-750.
BRENNAN, J., delivered the opinion for a unanimous Court.