Graham v. Bowen

Summary

The court rejected a constitutional challenge to the suspension of Social Security retirement benefits for incarcerated felony prisoners under 42 U.S.C. § 402(x)(1). It held that the provision did not violate equal protection or the Ex Post Facto Clause and declined to certify a class action. Final judgment was entered for the Secretary of Health and Human Services.

Holdings

1. The denial of Social Security retirement benefits to felony prisoners does not violate equal protection because prisoners are not a suspect class, the affected interest is ordinary rather than fundamental, and denying benefits to prisoners otherwise supported by the government bears a rational or fair and substantial relation to legitimate legislative objectives.
2. Suspending Social Security retirement benefits for felony prisoners does not violate the Ex Post Facto Clause because the provision is civil and regulatory rather than a criminal punishment or an increase in punishment for a completed offense.
3. The proposed class should not be certified.

Questions Presented

1. Whether suspending Social Security retirement benefits for individuals imprisoned for felonies violated equal protection.
2. Whether applying the benefit-suspension provision to prisoners who had already committed their felonies violated the Ex Post Facto Clause.
3. Whether the plaintiffs' proposed nationwide class should be certified.

Disposition

other