Califano v. Jobst

In Califano v. Jobst (1977) 434 U.S. 47, the court held that a rational basis existed for terminating benefits to certain dependents upon marriage while continuing benefits to certain others. First, the court found that "both tradition and common experience support the conclusion that marriage is an event which normally marks an important change in economic status," (p. 53) and that "it was rational for Congress to assume that marital status is a relevant test of probable dependency." ( Pp. 53-54.) "Instead of requiring individualized proof on a case by case basis, Congress has elected to use simple criteria, such as age and marital status, to determine probable dependency . . . . There is no question about the power of Congress to legislate on the basis of such factual assumptions. General rules are essential . . . even though such rules inevitably produce seemingly arbitrary consequences in some individual cases." ( Pp. 52-53.) Since the distinction made by the act between married and unmarried persons is not irrational, "the general rule, terminating upon marriage the benefits payable to a secondary beneficiary, is unquestionably valid." ( P. 54.) Next, the court found that a rational basis existed for the exception which continued benefits in the instance of marriage between beneficiaries. The court declared "it was reasonable for Congress to ameliorate the severity of the general rule by protecting both spouses from the dual hardship which it effected" (p. 55), and it interpreted the exception as a "reliable indicator of probable hardship." ( P. 57.)