Richardson v. Belcher

Background

Raymond Belcher, a disabled worker, was approved for Social Security disability benefits in October 1968 worth $329.70 per month for his family. In January 1969 the federal payment was cut to $225.30 after officials found he also received $203.60 per month from West Virginia workmen’s compensation. He sued, claiming the reduction violated the Fifth Amendment’s guarantee of due process. The District Court struck down the offset and the Secretary appealed to this Court.

Reasoning

The Court considered whether Congress may reduce Social Security disability benefits when a recipient also gets state workmen’s compensation. The majority relied on earlier decisions that allow Congress to change benefit rules and said this case raised a substantive, not procedural, question. It found a rational basis in the statute’s history: Congress sought to avoid overly duplicative payments, to preserve state compensation programs, and to limit total payments to 80% of prior earnings. Applying that standard, the Court reversed and upheld the offset as constitutional.

Real world impact

The decision allows the federal government to reduce Social Security disability checks for people who also get state workmen’s compensation, so some disabled workers and their families will receive smaller federal payments. The ruling resolves the constitutional challenge in favor of the Government and leaves the offset in place unless changed later by Congress or another court.

Dissents or concurrances

Justices Douglas and Marshall (joined by others) dissented, arguing the offset irrationally singled out workmen’s compensation and unfairly lowered income for certain disabled families; they would have upheld the District Court’s decision.