434 U.S. 47 (1977)
Mr. Jobst has been disabled by cerebral palsy since his birth in 1932.1 He qualified for child’s insurance benefits in 1957, several months after his father died.2 In 1970 he married another cerebral palsy victim.3 Since his wife was not entitled to benefits under the federal Act, the statute required the Secretary to terminate his benefits.4
Mr. Jobst brought this suit to review the Secretary’s action.5 The District Court held that the statute violated the equality principle applicable to the Federal Government by virtue of the Fifth Amendment because all child’s insurance beneficiaries are not treated alike when they marry disabled persons.6 Beneficiaries who marry other social security beneficiaries continue to receive benefits whereas those who marry nonbeneficiaries lose their benefits permanently.7 The court held this distinction irrational.8
The Secretary appealed directly to this Court.9 Noting that Mr. Jobst and his wife had become entitled to benefits under a newly enacted statute authorizing supplemental security income for the aged, blind, and disabled, this Court remanded the case for reconsideration in the light of that program.10 The District Court reviewed the new program, concluded that it had no relevance to the issues presented by this case, and reinstated its original judgment.11 The Secretary again appealed, and the Supreme Court noted probable jurisdiction.12
As originally enacted in 1935, the Social Security Act authorized a monthly benefit for qualified wage earners at least 65 years old.13 In 1939 Congress created secondary benefits for wives, children, widows, and parents of wage earners.14 In 1956, Congress enlarged the class of persons entitled to a child’s benefit to include those who were under a disability which began before age 18.15 In 1958, Congress adopted an amendment providing that marriage would not terminate a child’s disability benefit if the child married a person who was also entitled to benefits under the Act.16
Whether Congress has the power to require that a dependent child's social security benefits terminate upon marriage even though his spouse is permanently disabled?17
Congress may legislate on the basis of factual assumptions such as marital status to determine probable dependency for social security benefits. General rules are essential for efficient administration of the trust fund even if they produce arbitrary consequences in individual cases.18 The Social Security Act creates a trust fund financed largely by taxes on wage earners, with secondary benefits predicated on relationship to the contributing wage earner rather than individualized need.19 Congress elects simple criteria like age and marital status instead of case-by-case proof of dependency because such rules enable manageable administration of a program of this scale.20 A distinction between married and unmarried persons rests on the rational assumption, supported by tradition and common experience, that marriage normally marks an important change in economic status and reduces the likelihood of continued parental dependency.21
Yes. Mr. Jobst, disabled by cerebral palsy since birth in 1932, qualified for child’s insurance benefits in 1957 after his father’s death and lost those benefits in 1970 upon marrying another cerebral palsy victim who was not entitled to social security benefits.22 The statutory termination rule applied directly because Congress had reasonably assumed that marriage alters economic status, rendering the beneficiary less likely to remain dependent on the wage earner’s support.23 This assumption holds even though Mr. Jobst’s spouse was also disabled, because the rule employs a general criterion rather than requiring individualized determinations of hardship.24
The distinction is not drawn on irrelevant grounds such as race or religion but on marital status, which bears a clear relation to probable dependency within the complex trust-fund structure of the Act.25
Congress therefore possesses the constitutional power under the Fifth Amendment to require termination of a dependent child’s social security benefits upon marriage. The general rule satisfies due process requirements when applied to the facts of Mr. Jobst’s marriage to a non-beneficiary.26
Whether the 1958 amendment creating an exception for marriages between beneficiaries invalidates the general requirement that benefits terminate upon marriage?27
The 1958 amendment created a limited exception for marriages between persons already receiving benefits.28 This exception does not invalidate the general marriage-termination rule. The exception rests on a reasonable legislative judgment that such marriages do not characteristically produce the same economic change. The exception is simple to administer without individualized inquiries into need.29 Both the general rule and the exception are judged by characteristics typical of the affected classes rather than atypical examples.30 Congress may take one firm step toward alleviating hardship without extending relief to every similar situation in a single statute.31 The exception avoids periodic review of continued entitlement.32 It introduces no new administrative concepts into the trust-fund program.33
No. Although the 1958 amendment protects marriages between two beneficiaries from termination, Mr. Jobst married a disabled non-beneficiary and therefore remained subject to the general rule that had applied since 1939.34 The classification is not limited to disabled persons; it affects widows, widowers, parents, and divorced wives as well, and the exception itself encompasses a broader group than the District Court described. When judged by typical characteristics, the exception rationally addresses the dual hardship that occurs when two beneficiaries marry and lose both sets of benefits, while the limits preserve administrative simplicity and avoid any necessity for case-by-case determinations of disability or need.35 The amendment therefore leaves the general rule intact and does not render it irrational.36
The 1958 amendment does not invalidate the general requirement that benefits terminate upon marriage, and both the rule and the exception constitute legitimate exercises of Congress’s power to allocate benefits from the social security trust fund.37