Weinberger v. Salfi

1975-06-26

Headline: Court upholds Social Security’s nine‑month marriage rule, reversing a lower court and limiting class-wide relief while leaving individual survivors to pursue agency review for benefits.

Holding: The Court ruled that the district court lacked general federal-question jurisdiction over class claims, that the named women could sue under the Social Security Act’s administrative-review process, and that the nine‑month marriage rule is constitutional.

Real World Impact:

Upheld nine‑month rule, keeping many short‑marriage applicants from automatic benefits.
Restricts classwide court orders; unnamed claimants must use agency review first.
Affirms Congress’s power to use simple eligibility rules to deter abuse.

Topics: Social Security, survivors benefits, marriage rules, administrative review, class actions

Summary

Background

A widow and her daughter challenged Social Security rules that deny survivor benefits when a marriage or stepchild relationship lasted less than nine months before the wage earner’s death. Mrs. Salfi married in May 1972 and her husband died less than six months later; the agency denied benefits and a three-judge federal court certified a class, declared the nine‑month rule an unconstitutional irrebuttable presumption, and ordered benefits for the class.

Reasoning

The Supreme Court first addressed where these claims belong. It held the district court lacked broad federal-question jurisdiction over unnamed class members, but that the named women could proceed under the Social Security Act’s built-in review route because the agency’s reconsideration was treated as a final decision for them. On the constitutional question the Court applied the ordinary rational-basis standard for social-welfare rules and concluded Congress could use a simple, objective nine‑month rule as a prophylactic way to limit sham marriages and to ease administration. The Court distinguished cases that struck down conclusive presumptions tied to basic personal liberties, finding those precedents inapplicable to noncontractual benefit rules.

Real world impact

The ruling reverses the lower court’s classwide award and leaves many short‑marriage applicants to seek relief through the agency’s review process or under the statute’s procedures. It affirms that Congress may set bright‑line eligibility tests to deter abuse and to simplify administration. The decision is a final merits ruling reversing the District Court.

Dissents or concurrances

Justices Brennan and Marshall would have held the nine‑month rules unconstitutional and found broader federal-question jurisdiction; Justice Douglas emphasized the right to a jury trial and would have remanded so the widow could prove her marriage was not a sham.