Wengler v. Druggists Mutual Insurance

1980-04-22

Headline: A Missouri workers’ compensation rule favoring widows is struck down for sex-based discrimination, ending automatic death-benefit presumptions and sending the dispute back to state courts to fix how survivors are treated.

Holding: The Court reversed and held that Missouri’s sex-based presumption favoring widows violates the Constitution’s guarantee of equal treatment, and sent the case back for state courts to decide an appropriate remedy.

Real World Impact:

Ends sex-based automatic presumption of widow dependency in Missouri workers’ compensation.
State courts must decide how to fix the statute and treat spouses equally.
Protects working women from laws that provide less family protection based on sex.

Topics: gender discrimination, workers' compensation, survivor benefits, spousal rights

Summary

Background

A Missouri woman, Ruth Wengler, died in a work accident and her husband, Paul Wengler, sought death benefits under a state law that automatically presumed a widow dependent but required a widower to prove incapacity or actual dependence. The couple’s dispute moved through state courts: a trial court awarded benefits, the Missouri Supreme Court reversed, and the U.S. Supreme Court agreed to review the constitutional question.

Reasoning

The Court asked whether the law’s different rules for surviving husbands and wives comport with the Constitution’s promise of equal treatment (the Equal Protection Clause). Relying on prior decisions, the Court said sex-based classifications must serve important government goals and be closely tied to achieving those goals. Missouri’s justification—that presumptions for women save administrative effort—was insufficient. The Court held the statute’s automatic presumption discriminated on the basis of sex and could not be justified by mere administrative convenience, so it reversed the state high court’s decision.

Real world impact

The ruling invalidates the Missouri rule that treated surviving spouses differently by sex. The Supreme Court sent the case back to the Missouri courts to decide how to remedy the problem, leaving state judges (or the legislature) to choose whether to extend the presumption to widowers or remove it for widows. As an example in the opinion, Mrs. Wengler earned $69 per week and the husband would have received $46 weekly under the statute.

Dissents or concurrances

Justice Stevens wrote separately, emphasizing that the statute primarily disadvantaged men in practice, while Justice Rehnquist dissented and would have upheld the Missouri decision.