CALIFANO V. WEBSTER
430 U.S. 313 (1977)
NATURE OF THE CASE: This was a dispute over social security discrimination in retirement
benefits.
FACTS: The Social Security Act computed old-age insurance benefits on the basis of the
wage earner's 'average monthly wage' earned during his 'benefit computation years' which are
the 'elapsed years' (reduced by five) during which the wage earner's covered wages were
highest. Until a 1972 amendment, 'elapsed years' depended upon the sex of the wage earner.
This case started as a review under 205(g) of the Social Security Act from a denial, after
hearing, of appellee's request that a more favorable formula be used to compute his
benefits. The court held that the statutory scheme violated equal protection in that to give
women who reached age 62 before 1975 greater benefits than men of the same age and earnings
was irrational, and that the 1972 amendment was to be construed to apply retroactively,
because construing the amendment to give men who reach age 62 in 1975 or later the benefit
of the 1972 amendments but to deny older men the same benefit would render the amendment
irrational, and therefore unconstitutional.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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