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Schweiker v. Hogan, 457 U.S. 569 (1982)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Schweiker v. Hogan, 457 U.S. 569 (1982)
Schweiker v. Hogan No. 81-213 Argued March 24, 1982 Decided June 21, 1982 457 U.S. 569
APPEAL FROM THE UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF MASSACHUSETTS
Syllabus
Section 1903(f) of the Social Security Act provides that federal reimbursement to States electing to provide Medicaid benefits to the "medically needy" is available only if the income of those persons, after deduction of incurred medical expenses, is less than 133 1/3% of the state Aid to Families With Dependent Children (AFDC) payment level. Section 1903(f) specifically excepts from this rule the "categorically needy" -- those receiving Supplemental Security Income (SSI) because of lack of income to meet their basic needs. As applied in Massachusetts, § 1903(f) results in a distribution of Medicaid benefits to recipients of SSI that is more generous than the distribution of such benefits to persons who are self-supporting. Appellees, each of whom (or his spouse) receives Social Security benefits in an amount that renders him ineligible for either SSI benefits or state supplementary payments, filed suit in Federal District Court, alleging that § 1903(f), as applied in Massachusetts, violates the equal protection component of the Fifth Amendment. Appellees asserted that, since 133 1/3% of the Massachusetts AFDC payment level is for them lower than the SSI payment level, they are ineligible for Medicaid until their income, after deduction of incurred medical expenses, is less than that of SSI payment recipients, and that, because of the Social Security benefits which they receive, appellees thus have less income available for nonmedical expenses than individuals who -- possibly because they never worked and receive no Social Security benefits -- are dependent upon public assistance for support. The District Court entered judgment for appellees.
Held:
1. There is no merit to appellees’ contention that the Social Security Act itself compels the conclusion that, if Medicaid services are provided to the "medically needy," those persons may not be forced to incur medical expenses that would reduce their remaining income below the applicable public assistance standard. The legislative history of the Medicaid provisions of the Act does not justify a departure from the literal and clear language of § 1903(f). Nor does 1903(f)’s literal language conflict with any other provision of the Act. Moreover, adherence to that section’s language is consistent with its interpretation by the Secretary of Health and Human Services. Thus, the discrimination challenged in this case is required by the Social Security Act. Pp. 584-588.
2. As applied in Massachusetts, § 1903(f) does not violate constitutional principles of equal treatment. While powerful equities support appellees’ claim of unfair treatment insofar as they receive less medical assistance and have less income remaining for their nonmedical needs than do SSI recipients, a belief that an Act of Congress may be inequitable or unwise is an insufficient basis on which to conclude that it is unconstitutional. The optional character of the congressional scheme -- whereby participating States must provide Medicaid benefits to the categorically needy but may elect not to provide any benefits at all to the medically needy -- does not itself violate constitutional principles of equality. Since a State may deny all benefits to the medically needy -- while providing benefits to the categorically needy and rendering some persons who are on public assistance better off than others who are not -- it may narrow the gap between the two classes by providing partial benefits to the medically needy even though certain members of that class may remain in a position less fortunate than those on public assistance. The fact that Massachusetts has provided Medicaid benefits to the medically needy does not force it to make immediate medical need the sole standard in its entire Medicaid program. Pp. 588-593.
501 F.Supp. 1129, reversed and remanded.
STEVENS, J., delivered the opinion for a unanimous Court.
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Chicago: U.S. Supreme Court, "Syllabus," Schweiker v. Hogan, 457 U.S. 569 (1982) in 457 U.S. 569 457 U.S. 570–457 U.S. 571. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=HR76SD8B1LXLB2L.
MLA: U.S. Supreme Court. "Syllabus." Schweiker v. Hogan, 457 U.S. 569 (1982), in 457 U.S. 569, pp. 457 U.S. 570–457 U.S. 571. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=HR76SD8B1LXLB2L.
Harvard: U.S. Supreme Court, 'Syllabus' in Schweiker v. Hogan, 457 U.S. 569 (1982). cited in 1982, 457 U.S. 569, pp.457 U.S. 570–457 U.S. 571. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=HR76SD8B1LXLB2L.
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