Wengler v. Druggists Mutual Insurance Co.
United States Supreme Court
446 U.S. 142, 100 S. Ct. 1540, 64 L. Ed. 2d 107 (1980)
- Written by Serena Lipski, JD
Facts
Ruth Wengler, an employee of Druggists Mutual Insurance Co. (Druggists) (defendant), died in a work-related accident. Ruth’s husband, Paul J. Wengler, filed a claim for workers’-compensation death benefits. The Missouri workers’-compensation statute governing death benefits required that to be eligible, a widower had to demonstrate physical or mental incapacity or actual dependence on his wife’s earnings. The statute placed no such limitations on a widow’s eligibility for death benefits. Paul was neither incapacitated nor actually dependent on Ruth’s earnings, and therefore he was denied benefits. Paul appealed, arguing that the Missouri statute violated the Equal Protection Clause of the Fourteenth Amendment. No evidence was presented regarding the economic consequences of the statute to the state or beneficiaries. The circuit court agreed with Paul and reversed the administrative decision. Druggists appealed, and the Missouri Supreme Court reversed the circuit court’s decision, reasoning that the statute did not discriminate against widowers but instead favored widows based on the substantive difference in the economic status of men and women. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (White, J.)
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