Califano v. Westcott

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Unemployment insurance


Supreme Court of the United States
Califano v. Westcott
Reference: 443 U.S. 76
Term: 1979
Important Dates
Argued: April 16, 1979
Decided: June 25, 1979
Outcome
United States District Court for the District of Massachusetts affirmed
Majority
Byron WhiteJohn StevensWilliam BrennanHarry BlackmunThurgood Marshall
Dissenting
Lewis PowellWarren BurgerWilliam RehnquistPotter Stewart

Califano v. Westcott was a case decided on June 25, 1979, by the United States Supreme Court, which ruled that the state could not deny Aid to Families with Dependent Children, Unemployed Father (AFDC-UF) benefits to families that otherwise qualified for benefits but where the female spouse was unemployed (not the father). The Supreme Court affirmed the lower court's decision and held that Section 407 of the Social Security Act (which governed the AFDC-UF program) discriminated against families where the female spouse was a wage earner, violating the Due Process Clause of the Fifth Amendment.[1][2]

Background

Couples Cindy and William Westcott and Susan and John Westwood each had infant children and satisfied all requirements to receive aid through the joint federal-state Aid to Families with Dependent Children, Unemployed Father (AFDC-UF) program. The state of Massachusetts deemed the families ineligible for aid since both fathers had insufficient work histories. Both mothers were the primary earners in their families until they became unemployed. They would have qualified for benefits under AFDC-UF if they were male. The families filed suit in the United States District Court for the District of Massachusetts, alleging the statute establishing AFDC-UF (Section 407 of the Social Security Act) discriminated on the basis of gender, violating the Fifth and Fourteenth Amendments.[1][2]

The district court found the law unconstitutional and ordered the expansion of the AFDC-UF program to all families with needy children where either parent was unemployed.[1][2]

Oral argument

Oral argument was held on April 16, 1979. The case was decided on June 25, 1979.[1]

Decision

The Supreme Court decided 5-4 that Section 407 of the Social Security Act discriminated against families where the female spouse was a wage earner, violating the Due Process Clause of the Fifth Amendment. Justice Harry Blackmun delivered the opinion of the court, joined by Justices Byron White, John Stevens, William Brennan, and Thurgood Marshall. Justice Lewis Powell filed an opinion concurring in part and dissenting in part, joined by Chief Justice Warren Burger and Justices William Rehnquist and Potter Stewart.[1]

Opinions

Opinion of the court

Justice Harry Blackmun, writing for the court, argued that Section 407 of the Social Security Act discriminated against families where the female spouse was a wage earner, violating the Due Process Clause of the Fifth Amendment. Blackmun also said Section 407 was not significantly related to a government goal. The court upheld the district court's expansion of payments to families with female wage earners:[1]

For mothers who are the primary providers for their families, and who are unemployed, § 407 is obviously gender-biased, for it deprives them and their families of benefits solely on the basis of their sex. The Secretary's argument, at bottom, turns on the fact that the impact of the gender qualification is felt by family units, rather than individuals. But this Court has not hesitated to strike down gender classifications that result in benefits being granted or denied to family units on the basis of the sex of the qualifying parent. See Frontiero v. Richardson, 411 U. S. 677 (1973) (military quarters allowances and medical and dental benefits); Weinberger v. Wiesenfeld, 420 U. S. 636 (1975) (survivor's benefits); Califano v. Goldfarb, 430 U. S. 199 (1977) (survivor's benefits); Califano v. Jablon, 430 U.S. 924 (1977), summarily aff'g 399 F. Supp. 118 (Md.1975) (spousal benefits). Here, as in those cases, the statute "discriminates against one particular category of family -- that in which the female spouse is a wage earner." Goldfarb, 430 U.S. at 430 U. S. 209 (plurality opinion). ...


The deprivation imposed by § 407, moreover, is not a mere procedural barrier, like the proof-of-dependency requirement in Frontiero and Goldfarb, but is an absolute bar to qualification for aid. We therefore reject the contention that the classification imposed by § 407 does not discriminate on the basis of gender. ...

We conclude that the gender classification of § 407 is not substantially related to the attainment of any important and valid statutory goals. It is, rather, part of the "baggage of sexual stereotypes," Orr v. Orr, 440 U.S. at 440 U. S. 283, that presumes the father has the "primary responsibility to provide a home and its essentials," Stanton v. Stanton, 421 U. S. 7, 421 U. S. 10 (1975), while the mother is the "center of home and family life.'" Taylor v. Louisiana, 419 U. S. 522, 419 U. S. 534 n. 15 (1975). Legislation that rests on such presumptions, without more, cannot survive scrutiny under the Due Process Clause of the Fifth Amendment.

Under these circumstances, any fine-tuning of AFDC coverage along "principal wage-earner" lines is properly left to the democratic branches of the Government. In sum, we believe the District Court, in an effort to render the AFDC-UF program gender-neutral, adopted the simplest and most equitable extension possible.[3]

—Justice Benjamin Cardozo, majority opinion in Califano v. Westcott[1]

Dissenting opinions

Justice Lewis Powell, dissenting in part and concurring in part, agreed Section 407 violated the Fifth Amendment, but he said the court should have ended payments under the section instead of expanding payments to families with female wage earners:[1]

We cannot predict what Congress will think to be in the best interest of its total welfare program. The extension of AFDC benefits to families suffering only from unemployment was a relatively recent development in the history of the program, a development that Congress made permanent only on the understanding that payments could be limited to cases where the principal wage earner was out of work. We cannot assume that Congress, in 1968, would have approved this extension if it had known that ultimately payments would be made whenever either parent became unemployed. Nor can we assume that Congress now would adopt such a system in light of the Court's ruling that § 407 is invalid.[3]
—Justice Lewis Powell, dissenting opinion in Califano v. Westcott[1]

See also

External links

Footnotes