Supreme Court of the United States

Schweiker v. Hogan

June 21, 1982457 U.S. 569

Summary

The Court held that the Medicaid statute required Massachusetts to apply the statutory income limit to medically needy recipients, even when that limit left some Social Security recipients with less income for nonmedical needs than SSI recipients. It further held that this statutory classification was rational and did not violate the equal protection component of the Fifth Amendment because Congress could limit federally funded Medicaid benefits to persons deemed most needy. The District Court's constitutional judgment was reversed and the case was remanded.

Holding

  • Statutory interpretation of the Medicaid income limit. The Social Security Act expressly limited federal reimbursement for medically needy benefits to individuals whose income, after deduction of incurred medical expenses, was below 133 1/3% of the applicable state AFDC payment level. The Act did not require medically needy recipients to retain income comparable to that of categorically needy or SSI recipients.
  • Equal protection challenge to the Medicaid classification. Applying the statutory limit to medically needy persons in Massachusetts did not violate equal protection. Congress rationally could distinguish categorically needy persons from persons with greater gross income and could allocate limited medical assistance primarily to those regarded as most impoverished, even though some medically needy individuals were worse off after medical expenses than some categorically needy individuals.

Docket 81-213

Cited authorities

  • 42 U.S.C. §§ 1381-1385
  • 81 Stat. 898
  • 42 U.S.C. § 1396
  • 79 Stat. 345
  • 79 Stat. 345
  • 79 Stat. 345
  • 79 Stat. 346
  • 81 Stat. 898

Cited by

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