|
''Geduldig v. Aiello'', , was an equal protection case in the United States in which the Supreme Court ruled on whether unfavorable treatment to pregnant women could count as sex discrimination. It held that the denial of insurance benefits for work loss resulting from a normal pregnancy did not violate the Fourteenth Amendment. The California insurance program at issue did not exclude workers from eligibility based on sex but did exclude pregnancy from a list of compensable disabilities. The majority found that even though only women would be directly affected by the administrative decision, the classification of normal pregnancy as non-compensable was not a sex-based classification, and therefore the court would defer to the state so long as it could provide a rational basis for its categorization. ==Facts== From 1946, California ran an insurance system to cover private sector employees if temporarily unemployed because of a disability not covered by workmen’s compensation. It was funded by contributions deducted from the wages of participating employees, for whom participation was generally mandatory unless they belonged to an approved private insurance plan. Employees who had contributed 1% of a minimum income to the disability fund for one year prior to a period of disability were eligible to receive benefits. However, certain disabilities would not be covered, including those resulting from commitment for dipsomania, drug addiction, or sexual psychopathy.〔In his dissent, Justice Brennan pointed out that at oral arguments, the Deputy Attorney General of California testified that such commitments for these conditions were “fairly archaic” and did not realistically constitute “valid exclusions” from the insurance program.〕 In ''Geduldig'', the appellees challenged the further exclusion of certain disabilities resulting from pregnancy, as found in §2626 of the Unemployment Insurance Code: “In no case shall the term ‘disability’ or ‘disabled’ include any injury or illness caused by or arising in connection with pregnancy up to the termination of such pregnancy and for a period of 28 days thereafter.” The litigation began as two separate class action suits brought by employees who had paid into the state’s disability fund but who had been denied benefits relating to pregnancy-related disabilities. Three of the employees suffered employment disability after complications that arose during their pregnancies, while the fourth experienced a normal pregnancy which still led to a temporary inability to work. Carolyn Aiello brought suit in Federal District Court, while Augustina Armendariz, Elizabeth Johnson, and Jacqueline Jaramillo brought suit as a petition for a writ of mandate in the state’s supreme court. The separate cases were consolidated when the state suit was removed to federal court by the appellant, Dwight Geduldig, Director of the California Department of Human Resources Development. Initially, the appellees sought to enjoin enforcement of the exclusionary policy, and the District Court, as a divided three-judge panel, granted their motion for summary judgment, holding that the program’s administration violated the Fourteenth Amendment’s Equal Protection Clause and stating that “the exclusion of pregnancy-related disabilities is not based upon a classification having a rational and substantial relationship to a legitimate state purpose.” The court further denied a motion to stay its judgment pending appeal. The appellant proceeded to file a similar motion with the Supreme Court, which noted probable jurisdiction of the appeal. Although three of the appellees brought suit to recover benefits for loss of work after complications from pregnancy (tubal and ectopic pregnancies and a miscarriage), this issue was moot by the time the case reached the Supreme Court due to a decision in another case. In ''Rentzer v. California Unemployment Insurance Appeals Board,'' the state court interpreted the statute as applying only to benefit payments for disabilities resulting from normal pregnancies, thus allowing a woman who had suffered an ectopic pregnancy to recover benefits.〔 ''Rentzer v. California Unemployment Insurance Appeals Board,'' 32 Cal. App.3d 604, 108 Cal. Rptr. 336 (Cal. App.2.Dist. 1973). 〕 Therefore, the only remaining live controversy in ''Geduldig'' was whether appellee Jaramillo and others similarly situated were entitled to benefits for work loss related to normal and generally healthy pregnancy and childbirth. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Geduldig v. Aiello」の詳細全文を読む スポンサード リンク
|