Astrue v. Capato
Astrue v. Capato Background Information:
The case of Astrue v. Capato concerned the right of twin children to procure children’s social security survivor benefits. The children in question were born to Karen Capato in September of 2003. Approximately four years before their birth, Karen married Robert Capato. Following their marriage, Robert was diagnosed with cancer and was informed that treatments might leave him infertile. Before undergoing cancer treatment, Robert deposited his semen with a local sperm bank to preserve the possibility of procreating with Karen. The couple ended up having one child through intercourse in 2001, but this child’s eligibility for benefits was not of importance to the case of Astrue v. Capato. Unfortunately, Mr. Capato passed away in 2001.
Following Mr. Capato’s death, Karen underwent treatment for in vitro fertilization using her ova and Robert’s semen. This operation requires the extraction of the ova from the body. Once extracted the ova are then fertilized with sperm outside the female’s body. The fertilized are then transferred to the woman for gestation purposes. Mrs. Capato, as a result of this procedure, gave birth to twin children in September of 2003—18 months following Robert’s death.
Shortly after the birth of the twins, Karen sough Social Security survivor benefits on their behalf. These requests; however, were ultimately denied by the Social Security Administration. The denial was affirmed by an administrative law judge and subsequently by a federal district judge on the grounds that the twins were not eligible to recover under the definitions of “children” included in the Social Security Act.
The United States Court of Appeals for the Third Circuit reversed this decision, claiming that even though the twins did not qualify under the explicit definitions laid forth in the act, the children nonetheless should be deemed eligible because they were the biological children of a deceased earner and his widow.
Mrs. Capato’s argument in Astrue v. Capato revolved around the premise that biologically connected children are the beneficiaries of the benefits program.
Astrue v. Capato: The Decision
The case of Astrue v. Capato was decided by the United States Supreme Court. The Court in Astrue v. Capato unanimously rejected the mother’s arguments. In the opinion offered by Associate Justice Ruth Bader Ginsburg, nothing indicated that Congress intended biological parents to be a fundamental prerequisite for the definition of “child” under the Act.
The United States Supreme Court in Astrue v. Capato ruled that a child conceived and born after a parent’s death cannot solely rely on genetic connections to the deceased to secure eligibility for Social Security Survivor Benefits. The Supreme Court in Astrue v. Capato ultimately sided with the Social Security Administration’s interpretation of the law, for it held that all children, including those born via procedure, must either demonstrate that they would have secured eligibility to inherit from their deceased parent under state law or that they have satisfied one of the statutory alternative to the requirement. The Social Security Administration’s interpretation was deemed more consistent with the core purpose of the legislation, which is to provide aid and protection to family members who depend on another member’s income from hardship if that family member happens to die early.
The case of Astrue v. Capato was decided via a 9-0 vote.
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