Califano v. Jobst

Background

A man born with cerebral palsy received child’s Social Security benefits after his father died. In 1970 he married another person with cerebral palsy who was not getting Social Security benefits, and the statute required termination of his child’s benefits. The District Court found the 1958 law irrational because it saved benefits when a beneficiary married another beneficiary but not when a beneficiary married a nonbeneficiary who was also disabled. The couple later became eligible for Supplemental Security Income and the case returned to the courts.

Reasoning

The key question was whether Congress can make marriage a rule for stopping dependent benefits and whether the 1958 exception for marriages between two beneficiaries is constitutional. The Court explained that Congress may use simple, easily applied rules like marital status as a reasonable way to decide probable dependency instead of individualized hearings. Congress had long ended child’s benefits upon marriage and later limited an exception to marriages where both spouses were already receiving Social Security benefits. The Court found those bright-line rules and the limited exception rational and administrable, and it reversed the lower court’s decision.

Real world impact

The decision means disabled dependents who marry someone not receiving Social Security benefits can lawfully lose their dependent payments even if the spouse is disabled. It affirms Congress’s choice to use clear rules rather than case-by-case need tests and notes that separate welfare programs, like Supplemental Security Income, exist to assist needy persons not covered by Social Security.