Thursday, November 14, 2013

Califano v. Webster case brief

Califano v. Webster case brief summary
430 U.S. 313 (1977)

Appellant, the Secretary of Health, Education, and Welfare, sought review of an order from the United States District Court for the Eastern District of New York reversing an administrative decision against appellee retired worker. The retired worker had requested that the formula used in a former version of § 215 of the Social Security Act, codified at 42 U.S.C.S. § 415, which favored females, be used to compute his retirement benefits.

The statutory scheme embodied in the former version of § 415 resulted in a higher "average monthly wage" and a correspondingly higher level of monthly old-age benefits for the retired female worker. Section 415 was amended to equalize the treatment of men and women but was not given retroactive application.


  • The Court held that old-age benefit payments were not constitutionally immunized against alterations of the kind at issue in the case and that Congress was authorized to replace one constitutional computation formula with another and to make the new formula prospective only. 
  • The former version of the challenged statute operated directly to compensate women for past economic discrimination and was deliberately enacted to compensate women for the particular economic disabilities they suffered. 
  • The subsequent amendment of § 415 was not a Congressional admission that its previous policy was invidiously discriminatory. 
  • The retired male worker's Fifth Amendment rights were not violated by the prospective application of § 415, as the Constitution did not forbid statutory changes to have a beginning and thus to discriminate between the rights of an earlier and later time.

The Court reversed the order overturning the administrative decision that refused to use the calculations from a former version of the Social Security Act to compute the retired male worker's retirement benefits.

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