Geduldig v Aiello

[417 U.S. 484, 1974]

TOPIC: Equal Protection Clause
PONENTE: Stewart, J

AUTHOR: ESCANO, Jovelan

NOTES: (if applicable)
The majority reaches its conclusions through viewing the
problem as one of underinclusive legislation, while the
dissent focuses on the inevitable connection of the unfunded
conditions with a single sex.

FACTS: (chronological order)

California operated a disability insurance system that supplemented workers compensation, in that it provided for
payments for disabilities not covered by workers compensation. The list of disabilities paid for by the State of California
was not exhaustive. Among those disabilities not paid for were certain pregnancy related conditions. Suit was brought
challenging the system as an unconstitutional gender-based classification.
ISSUE(S): Does the exclusion of the pregnancy-related conditions violate the Fourteenth Amendments Equal Protection
Clause?
HELD: No. Appeals Court ruling affirmed.
RATIO:
The list of conditions covered by the disability insurance system is not exclusive. Furthermore, there are conditions not
covered by the system that affect both men and women. The excluded conditions do not affect women alone.
The savings given the program by the exclusion of such conditions benefit both men and women. That is, inclusion of the
excluded conditions would result in lesser amounts of funding for all other conditions.
CASE LAW/ DOCTRINE:
Underinclusive legislation is appropriate under the Equal Protection Clause, so long as the line drawn by the State is
rationally supportable.
DISSENTING/CONCURRING OPINION(S):
Justice William Brennan (J. Brennan) argues that by disallowing payments related to pregnancy, the State inevitably
discriminates against women.