Heckler v. Mathews

Robert Mathews (defendant) retired in October 1977 with a government pension from the United States Postal Service (USPS). Mathews’s wife was already retired and entitled to full social security retirement benefits. In December 1977, Mathews applied for spousal benefits under his wife’s social security account. In the 1977 Amendments to the Social Security Act, Congress made spousal benefits available to all spouses; however, that availability was subject to offset if the recipient also received a government pension. Prior to 1977, only wives and dependent husbands could claim social security spousal benefits, but there was no pension offset. The 1977 Amendments contained a grace period under which the pre-1977 rules would determine spousal benefit eligibility for persons who became eligible for benefits prior to January 1977 and retired within five years. The Social Security Administration (SSA) (plaintiff) denied Mathews spousal benefits because, after applying the pension offset, two-thirds of his USPS pension payment was greater than his spousal benefit entitlement. Mathews challenged the denial, arguing it was unconstitutional for the pension offset grace period to apply to nondependent wives but not nondependent husbands. An administrative-law judge (ALJ) affirmed the denial. Mathews appealed. The federal district court reversed, holding the pension offset grace period violated equal protection because its applicability was based on gender. SSA appealed.