Geduldig v. Aiello
Citation and Court
417 U.S. 484 (1974) — Supreme Court of the United States
Facts
California’s disability insurance system paid benefits for a wide range of physical conditions but excluded from coverage disabilities arising from normal pregnancy and childbirth. Carolyn Aiello and other women challenged the exclusion as unconstitutional sex discrimination under the Equal Protection Clause of the Fourteenth Amendment.
Issue
Whether a state disability insurance system that excludes coverage for pregnancy-related disabilities discriminates on the basis of sex in violation of the Equal Protection Clause.
Holding
No. California’s exclusion of normal pregnancy from disability coverage does not constitute sex-based discrimination under the Equal Protection Clause; the classification is between pregnant persons and non-pregnant persons, not between women and men, and passes rational basis review.
Rule / Doctrine
Pregnancy classifications are not per se sex-based classifications for equal protection purposes. The relevant distinction is not between men and women but between two classes of people — those who are pregnant and those who are not — and the latter class includes members of both sexes. Under rational basis review, the state’s interest in maintaining a financially self-sustaining insurance program is sufficient justification.
Significance
Geduldig is highly controversial and was partially superseded by statute (the Pregnancy Discrimination Act of 1978) in the Title VII context. It illustrates the Court’s initial reluctance to treat pregnancy discrimination as sex discrimination, a position that has been widely criticized and limited. The case is taught to show the limits of formal equality analysis and its failure to account for sex-specific burdens.