Guadalupe Munoz v. Louis Sullivan, M.D., Secretary of the Department of Health and Human Services

OVERVIEW

Guadalupe Munoz filed suit against the Secretary of the Department of Health and Human Services (“the Secretary”), alleging that the six-month rule set forth in 42 U.S.C. § 1382c(b) (1983) is unconstitutional. Under the six-month rule, when a married couple, both of whom are eligible for Supplemental Security Income benefits, separate, they are paid benefits at the level set for married couples, rather than the higher level set for individuals, for a period of six months after the separation or until the marriage has ended. Munoz challenged the constitutionality of the six-month rule. She claimed that the benefit rate should be converted to the rate applicable to single persons immediately upon separation because the six-month rule bears no rational relationship to the purposes of the statute. She sought declaratory and injunctive relief for herself and for all similarly situated California residents.

The district court, applying the rational basis test, upheld the validity of the statutory rule. The court also denied Munoz’ motion for class certification, finding that it lacked subject matter jurisdiction over members of the proposed class. We affirm the district…