Townsend v. Swank

Townsend et al. v. Swank, Director, Department of Public Aid of Illinois, et al.
404 U.S. 282 (1971) |
SCOTUS decided 1971-12-20
Jurisdiction level:

Under the Supremacy Clause, the states do not have the option of denying AFDC benefits to needy dependent children between the ages of 18 and 21 who attend a college or university while granting these benefits to those who attended high school or a vocational training school.

Result: Win
Importance:

Maintained the view that states could not create AFDC eligibility conditions narrower than those of the federal Social Security Act and could not create exceptions.


Law type: Civil
Topic(s): Dependent children, Equal protection, Public assistance, and Supremacy clause
State of origin: IL
Attorneys:

Michael F. Lefkow argued the cause and filed briefs for appellants in No. 70-5021. M. James Spitzer, Jr., argued the cause pro hac vice for appellants in No. 70-5032. With him on the briefs was Melvin B. Goldberg. (Legal Assistance Foundation of Chicago)


Others involved: Under the Supremacy Clause, the states do not have the option of denying AFDC benefits to needy dependent children between the ages of 18 and 21 who attend a college or university while granting these benefits to those who attended high school or a vocational training school.
Organization role: Sponsor

Last modified: 2020-04-08 10:47
Case internal grade: A | Case internal status: OK |
Case internal status notes:
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For more info: Findlaw.com

CASE DETAILS

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)

Together with No. 70-5032, Alexander et al. v. Swank, Director, Department of Public Aid of Illinois, et al., also on appeal from the same court.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS

Syllabus

This class action challenges on equal protection and supremacy grounds an Illinois statute and regulation under which needy dependent children 18 through 20 years old attending high school or vocational training school qualify for benefits under the federally assisted Aid to Families With Dependent Children (AFDC) program, but such children attending a college or university do not qualify. A three-judge District Court upheld the Illinois scheme.

Held:

Under 402 (a) (10) of the Social Security Act, a state participating plan under the AFDC program must provide that aid to families with dependent children shall be furnished with reasonable promptness to “all eligible” individuals. Since 406 (a) (2) (B) of the Act makes dependent 18-20-year-olds eligible for benefits whether attending a college or university or a vocational or technical training course, and Congress has authorized no limitation of eligibility standards within the age group, the Illinois program conflicts with that federal statutory provision and violates the Supremacy Clause. Pp. 285-292.

314 F. Supp. 1082, reversed.