397 U.S. 471 (1970) |
SCOTUS decided 1970-04-06
A State has great latitude in dispensing its available funds for public welfare, and the State’s rationally supportable regulation does not violate the Equal Protection Clause.Result: Loss
Julie A. Nice, “A Sweeping Refusal of Equal Protection Dandridge v. Williams”, in Failinger and Rosser: “The Supreme Court’s decision in Dandridge v. Williams is one of the most significant cases not only in poverty law but also in constitutional law. Dandridge stands primarily for the proposition that courts should defer to the choices made by the political branches of government regarding how to allocate scarce resources spent on social welfare programs. In the lasting language of Justice Potter Stewart’s opinion for the Dandridge majority, “the intractable economic, social, and even philosophical problems presented by public welfare assistance programs are not the business of this Court.” Prior to the Dandridge decision, the Supreme Court had ruled in favor of poor people in several significant cases…. Dandridge abruptly ended this momentum toward equal constitutional protection of poor people. Since the Dandridge decision in 1970, courts have applied minimal rational basis review to public welfare programs….”
Law type: Civil
Topic(s): Deference to political branches, Equal protection, and Public assistance
State of origin: MD
Joseph A. Matera (Legal Aid Bureau of Baltimore), Baltimore, Md., for appellees
Organization role: Sponsor
Last modified: 2020-04-02 11:27
Case internal grade: A | Case internal status: OK |
Case internal status notes:
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CASE DETAILS(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)
APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
Appellees, large-family recipients of benefits under the Aid to Families With Dependent Children (AFDC) program, brought this suit to enjoin the application of Maryland’s maximum grant regulation as contravening the Social Security Act of 1935 and the Equal Protection Clause of the Fourteenth Amendment. Under the program, which is jointly financed by the Federal and State Governments, a State computes the “standard of need” of eligible family units. Under the Maryland regulation, though most families are provided aid in accordance with the standard of need, a ceiling of about $250 per month is imposed on an AFDC grant regardless of the size of the family and its actual need. The District Court held the regulation “invalid on its face for overreaching,” and thus violative of the Equal Protection Clause.
1. The Maryland regulation is not prohibited by the Social Security Act. Pp. 476-483.
(a) A State has great latitude in dispensing its available funds, King v. Smith, 392 U.S. 309, 318-319, and, given Maryland’s finite resources available for public welfare demands, it is not prevented by the Act from sustaining as many families as it can and providing the largest families with somewhat less than their ascertained per capita standard of need. Pp. 478-480.
(b) The statutory standard in § 402(a)(10) of the Act that aid “shall be furnished with reasonable promptness to all eligible individuals,” is not violated by the regulation, which does not deprive children of the largest families of aid, but reduces the family grant as a whole, and the Secretary of Health, Education, and Welfare has approved the Maryland scheme. Pp. 480-482.
(c) In its Social Security Amendments of 1967, Congress fully recognized that maximum grant regulations are permissible. Pp. 482-483. [p472]
2. The regulation does not violate the Equal Protection Clause. Pp. 483-487.
(a) The concept of overbreadth, though relevant where First Amendment considerations are involved, is not pertinent to state regulation in the social and economic field. Pp. 484-485.
(b) The regulation is rationally supportable and free from invidious discrimination, since it furthers the State’s legitimate interest in encouraging employment and in maintaining an equitable balance between welfare families and the families of the working poor. Pp. 486-487