Tuesday, November 5, 2013

Geduldig v. Aiello case brief

Geduldig v. Aiello case brief summary
417 U.S. 484 (1974)

CASE SYNOPSIS
Appellant director sought review of a decision of the United States District Court for the Northern District of California, which determined that a provision of a state disability insurance program violated the equal protection clause of U.S. Constitutional Amendment XIV and therefore enjoined its continued enforcement.

CASE FACTS
Appellant director sought review of an order that determined that a provision of a state disability insurance program violated the equal protection clause of U.S. Constitutional Amendment XIV and thus enjoined its continued enforcement. Appellee citizens, who were subject to a mandatory employment tax to fund the disability program, had argued that the program violated the Fourteenth Amendment because it precluded the payment of benefits for any disability resulting from pregnancy.


DISCUSSION

  • The court reversed and held that the exclusion of benefits due to disability from pregnancy did not result in invidious discrimination under the Equal Protection Clause. 
  • The court found that the program did not discriminate with respect to the persons or groups that were eligible for disability insurance protection under the program. 
  • The court held that the challenged classification related to the asserted underinclusiveness of the set of risks that the state had selected to insure. 
  • The court determined that although the state had created a program to insure most risks of employment disability, it was not required to insure all such risks based upon the minimal amount collected from each participating citizen.

CONCLUSION
The court reversed the decision of the district court, which determined that a provision of a state disability insurance program violated the equal protection clause, and therefore enjoined its continued enforcement. The court held that the program was proper because it did not discriminate with respect to persons or groups that were eligible for protection under program. Thus, the equal protection clause was not violated.

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