Weinberger v. Salfi
United States Supreme Court
422 U.S. 749 (1975)
Salfi's (plaintiff) husband died six months after their marriage despite being healthy when they wed; the Social Security Administration (defendant) denied her survivor benefits and her stepdaughter's benefits under a rule requiring at least nine months of marriage before death, without any opportunity for Salfi to prove her marriage was genuine. The district court invalidated the requirement as an impermissible irrebuttable presumption that short marriages were entered for improper benefit-seeking purposes, and the SSA appealed.
Whether, in seeking to protect against abuse of public funds, it is rational for Congress to rely on an irrebuttable presumption rather than case-by-case determinations, given the costs and administrative burdens of individualized hearings.