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Califano v. Westcott
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| 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 White • John Stevens • William Brennan • Harry Blackmun • Thurgood Marshall | |
| Dissenting | |
| Lewis Powell • Warren Burger • William Rehnquist • Potter 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). ...
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” |
| —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
- Federalism
- Unemployment insurance
- The Hughes Court
- Supreme Court of the United States
- History of the Supreme Court
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 Justia, "Califano v. Westcott, 443 U.S. 76 (1979)," accessed November 8, 2021
- ↑ 2.0 2.1 2.2 Cornell Law School, "Joseph A. CALIFANO, Secretary of Health, Education, and Welfare, Appellant, v. Cindy WESTCOTT et al., John D. PRATT, etc., Appellant, v. Cindy WESTCOTT et al.," accessed August 27, 2021
- ↑ 3.0 3.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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