Geduldig v. Aiello
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| Geduldig v. Aiello | |
| Reference: 417 U.S. 484 | |
| Term: 1974 | |
| Important Dates | |
| Argued: March 26, 1974 Decided: June 24, 1974 | |
| Outcome | |
| United States District Court for the Northern District of California reversed | |
| Majority | |
| Warren Burger • Lewis Powell • William Rehnquist • Potter Stewart • Byron White • Harry Blackmun | |
| Dissenting | |
| William Brennan • Thurgood Marshall • William Douglas | |
Geduldig v. Aiello was a case decided on December 5, 1967, by the United States Supreme Court in which the court ruled that California could exclude women from claiming pregnancy-related disability benefits through the state’s unemployment disability insurance program.[1][2][3]
The Supreme Court reversed the lower court and held that the exclusion of pregnancy-related disabilities from the program did not discriminate against women in violation of the Equal Protection Clause of the Fourteenth Amendment.[1][2][3]
Background
Carolyn Aiello was temporarily unable to work due to a pregnancy-related disability. The state of California had a disability insurance system that required private employees to contribute to California's Disability Fund. The state paid benefits out of the fund to employees who became unable to work due to certain injuries or illnesses not covered by worker's compensation.[1][2][3]
Aiello applied for benefits from California's Disability Fund under Section 2626 of California's Unemployment Insurance Code, but the state denied her claim. The state citied the following text of Section 2626 in its decision: "In no case shall the term 'disability' or 'disabled' include any injury or illness caused by or arising in connection with pregnancy up to the termination of such pregnancy and for a period of 28 days thereafter."[1][2][3]
Aiello filed suit in United States District Court for the Northern District of California, alleging the exclusion of pregnancy-related disabilities under Section 2626 discriminated against women in violation of the Equal Protection Clause of the Fourteenth Amendment. The district court found the provision unconstitutional.[1][2][3]
Oral argument
Oral argument was held on March 26, 1974. The case was decided on June 24, 1974.[1][2]
Decision
The Supreme Court decided 6-3 that Section 2626 of California's Unemployment Insurance Code did not violate the Equal Protection Clause of the Fourteenth Amendment. Justice Potter Stewart delivered the opinion of the court, joined by Chief Justice Warren Burger and Justices Lewis Powell, William Rehnquist, Byron White, and Harry Blackmun. Justice William Brennan dissented, joined by Justices Thurgood Marshall and William Douglas.[1][2]
Opinions
Opinion of the court
Justice Potter Stewart, writing for the court, argued that Section 2626 of California's Unemployment Insurance Code did not violate the Equal Protection Clause of the Fourteenth Amendment. He argued that California had a compelling state interest in choosing what disabilities qualified for unemployment disability insurance benefits in order to maintain an adequate level of coverage for benefit recipients.[2]
| “ | The State has a legitimate interest in maintaining the self-supporting nature of its insurance program. Similarly, it has an interest in distributing the available resources in such a way as to keep benefit payments at an adequate level for disabilities that are covered, rather than to cover all disabilities inadequately. Finally, California has a legitimate concern in maintaining the contribution rate at a level that will not unduly burden participating employees, particularly low income employees who may be most in need of the disability insurance.
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” |
| —Justice Potter Stewart, majority opinion in Geduldig v. Aiello[2] | ||
Dissenting opinions
Justice William Brennan, writing the dissent, argued Section 2626 of California's Unemployment Insurance Code violated the Equal Protection Clause of the Fourteenth Amendment. He argued the failure to cover pregnancy-related conditions through the Disability Fund constituted sex discrimination:[2]
| “ | In my view, by singling out for less favorable treatment a gender-linked disability peculiar to women, the State has created a double standard for disability compensation: a limitation is imposed upon the disabilities for which women workers may recover, while men receive full compensation for all disabilities suffered, including those that affect only or primarily their sex, such as prostatectomies, circumcision, hemophilia, and gout. In effect, one set of rules is applied to females and another to males. Such dissimilar treatment of men and women, on the basis of physical characteristics inextricably linked to one sex, inevitably constitutes sex discrimination.[4] | ” |
| —Justice William Brennan, dissenting opinion in Geduldig v. Aiello[2] | ||
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 Oyez, "Geduldig v. Aiello," accessed November 17, 2021 Cite error: Invalid
<ref>tag; name "oyez" defined multiple times with different content - ↑ 2.00 2.01 2.02 2.03 2.04 2.05 2.06 2.07 2.08 2.09 2.10 Justia, "Geduldig v. Aiello, 417 U.S. 484 (1974)," accessed November 8, 2021
- ↑ 3.0 3.1 3.2 3.3 3.4 Cornell Law School, "Dwight GEDULDIG, etc., Appellant, v. Carolyn AIELLO et al.," accessed November 17, 2021
- ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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