Geduldig v. Aiello

Background

A state official in charge of California’s disability insurance program defended a law that excludes disabilities from normal pregnancy. Four women who had paid into the fund sued after each suffered pregnancy-related work disabilities; three had pregnancy complications and later received benefits after a state court limited the exclusion, but one woman with a normal pregnancy remained barred. The District Court earlier found the exclusion unconstitutional and enjoined enforcement.

Reasoning

The central question was whether excluding normal pregnancy from coverage unfairly discriminated against women. The majority said the program is structured like insurance, funded by a fixed one-percent employee contribution, and that the exclusion was a reasonable choice about which risks the State would insure to keep the fund solvent. The Court accepted the State’s claim that adding normal pregnancy would raise costs substantially and held that the classification was a permissible policy choice, reversing the District Court’s injunction.

Real world impact

As a result, California may continue to deny disability payments for routine pregnancy and childbirth while covering pregnancy complications. Three women with pregnancy complications received benefits after the state court’s limiting construction, but the woman whose disability came solely from normal pregnancy remains excluded. The ruling lets the State maintain contribution rates and current benefit levels rather than expand coverage.

Dissents or concurrances

A dissent argued the exclusion is sex discrimination because it singles out a condition unique to women, insisted on stricter review, and said cost savings alone do not justify denying benefits; the dissent pointed to feasible, less drastic alternatives suggested by the lower court.