417 U.S. 628 (1974) |
SCOTUS decided 1974-06-19
The Social Security Act, by deeming certain illegitimate children ineligible for disability insurance benefits, contravenes the Due Process Clause of the Fifth Amendment and the equal protection of the laws guaranteed thereby.Result: Win
Clarifies that certain illegitimate children are eligible for disability insurance benefits.
Law type: Civil
Topic(s): Disability: Benefits, Due process, Equal protection, and Illegitimate children
State of origin: IL
Jane G. Stevens argued the cause and filed briefs for appellants. (Legal Assistance Foundation of Chicago)
Organization role: Sponsor
Last modified: 2020-04-07 08:58
Case internal grade: A | Case internal status: OK |
Case internal status notes:
Lists: Important cases
For more info: Findlaw.com
CASE DETAILS(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)
Under the Social Security Act illegitimate children are deemed entitled to disability insurance benefits without any showing that they are in fact dependent upon their disabled parent if state law permits them to inherit from the wage-earner parent; if their illegitimacy results solely from formal, nonobvious defects in their parents’ ceremonial marriage; or if they are legitimated in accordance with state law. An illegitimate child unable to meet any of the foregoing conditions can qualify only if the disabled wage-earner parent contributed to the child’s support or lived with him prior to the parent’s disability, 42 U.S.C. 416(h)(3)(B); if the child is unable to meet any of the foregoing conditions, the statute bars the child’s benefits without any opportunity to establish entitlement thereto. Ramon Jimenez, a resident of Illinois (which does not allow nonlegitimated illegitimate children to inherit from their father), is a wage earner covered by the Act who became entitled to disability benefits in October 1963. Thereafter, Jimenez applied for insurance benefits for appellants, two of his nonlegitimated illegitimate children who were born after the onset of disability. The claims were denied since the children did not meet the requirements of 42 U.S.C. 416(h)(3)(B) or the other qualifying provisions of the Act. Appellants brought this action for review of the denial of benefits. A three-judge District Court upheld the statutory classification as being rationally related to the proper governmental interest of avoiding spurious claims. Held: Title 42 U.S.C. 416(h)(3)(B), as part of the statutory scheme applicable to illegitimates, contravenes the Due Process Clause of the Fifth Amendment and the equal protection of the laws guaranteed thereby. Pp. 631—638.
(a) ‘(T)he Equal Protection Clause (is violated by) discriminatory laws relating to status of birth where . . . the classification is justified by no legitimate state interest, compelling or otherwise.’ Weber v. Aetna Casualty & Surety Co., 406 U.S. 164, 176, 92 S.Ct. 1400, 31 L.Ed.2d 768. Dandridge v. Williams, 397 U.S. 471, 90 S.Ct. 1153, 25 L.Ed.2d 491, distinguished. Pp. 631—634.
(b) The primary purpose of the contested provision of the Act is to provide support for dependents of a disabled wage earner and is not, as appellee contends, to replace only that support actually enjoyed before the onset of disability. Pp. 634—635.
(c) The complete statutory bar to disability benefits imposed upon nonlegitimated afterborn illegitimates in appellants’ position, is not reasonably related to the valid governmental interest of preventing spurious claims. The potential for spurious claims is the same as to both. Even if children might rationally be classified on the basis of whether they are dependent upon their disabled parents, the Act’s definition of two subclasses of illegitimates is ‘overinclusive’ in that it benefits some children who are legitimated, or entitled to inherit, or illegitimate solely because of a defect in the marriage of their parents, but who are not dependent on their disabled parent. Conversely, the Act is ‘underinclusive’ in that it conclusively excludes some illegitimates in appellants’ subclass who are, in fact, dependent upon their disabled parent. Pp. 635—637.
(d) The judgment is vacated and the case is remanded to provide appellants an opportunity to establish their claim to eligibility as ‘children’ of the claimant eligible for benefits under the Act. Pp. 637—638.
353 F.Supp. 1356, vacated and remanded
From the opinion
The relevant facts are not in dispute. Ramon Jimenez, a wage earner covered under the Social Security Act, became disabled in April 1963, and became entitled to disability benefits in October 1963. Some years prior to that time, the claimant separated from his wife and began living with Elizabeth Hernandez, whom he never married. Three children were born to them, Magdalena, born August 13, 1963, Eugenio, born January 18, 1965, and Alicia, born February 24, 1968. These children have lived in Illinois with claimant all their lives; he has formally acknowledged them to be his children, has supported and cared for them since their birth, and has been their sole caretaker since their mother left the household late in 1968. Since the parents never married, these children are classified as illegitimate under Illinois law and are unable to inherit from their father because they are nonlegitimated illegitimate children. Ill.Ann.Stat., c. 3, § 12 (Supp.1974).
On August 21, 1968, Ramon Jimenez, as the father, filed an application for child’s insurance benefits on behalf of these three children. Magdalena was found to be entitled to child’s insurance benefits under the Social Security Act, and no issue is presented with respect to her claim. The claims of appellants, Eugenio and Alicia, were denied, however, on the ground that they did not meet the requirements of 42 U.S.C. 416(h)(3), since neither child’s paternity had been acknowledged or affirmed through evidence of domicile and support before the onset of their father’s disability.2 In all other respects Eugenio and Alicia are eligible to receive child’s insurance benefits, and their applications were denied solely because they are proscribed illegitimate children who were not dependent on Jimenez at the time of the onset of his disability.
Appellants urge that the contested Social Security provision is based upon the so-called ‘suspect classification’ of illegitimacy. Like race and national origin, they argue, illegitimacy is a characteristic determined solely by the accident of birth; it is a condition beyond the control of the children, and it is a status that subjects the children to a stigma of inferiority and a badge of opprobrium. We need not reach appellants’ argument, however, because in the context of this case it is enough that we note, as we did in Weber v. Aetna Casualty & Surety Co., 406 U.S. 164, 92 S.Ct. 1400, 31 L.Ed.2d 768 (1972):
‘The status of illegitimacy has expressed through the ages society’s condemnation of irresponsible liaisons beyond the bonds of marriage. But visiting this condemnation on the head of an infant is illogical and unjust. Moreover, imposing disabilities on the illegitimate child is contrary to the basic concept of our system that legal burdens should bear some relationship to individual responsibility or wrongdoing. Obviously, no child is responsible for his birth and penalizing the illegitimate child is an ineffectual—as well as an unjust—way of deterring the parent. Courts are powerless to prevent the social opprobrium suffered by these hapless children, but the Equal Protection Clause does enable us to strike down discriminatory laws relating to status of birth where . . . the classification is justified by no legitimate state interest, compelling or otherwise.’