Anderson v. Edwards

LOCATION: Ashtabula County

DOCKET NO.: 93-1883
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 514 US 143 (1995)
ARGUED: Jan 18, 1995
DECIDED: Mar 22, 1995

Dennis Paul Eckhart - on behalf of the Petitioners
Edwards - for herself
Katherine Meiss - on behalf of the Respondents
Paul A. Engelmayer - on behalf of the United States, as amicus curiae, supporting the petitioners

Facts of the case


Media for Anderson v. Edwards

Audio Transcription for Oral Argument - January 18, 1995 in Anderson v. Edwards

William H. Rehnquist:

We'll hear argument next in Number 93-1883, Eloise Anderson v. Verna Edwards.

Mr. Eckhart.

Spectators are admonished, do not talk or whisper in the courtroom.

If you're going to talk or whisper, get outside the courtroom.

Go ahead, Mr. Eckhart.

Dennis Paul Eckhart:

Mr. Chief Justice and may it please the Court:

The question presented by this case is whether, everything else being equal, a State may provide the same amount of AFDC benefits to a family where the dependent children are all related to their caretaker, but are not siblings of one another, as the State does where the children are all brothers and sisters of one another.

California and 28 other States have adopted a rule that requires the combination of assistance units when there are more... when there are two or more assistance units residing in the same household with the same caretaker relative.

California also requires the combination of assistance units if there are two caretaker relatives and they are married to each other.

The full text of California's regulation is set forth at the... in the appendix to the petition for certiorari at note 3 on page 17, note 3 in the district court opinion.

The fundamental error committed by the Ninth Circuit in this case, in the Beaton case, which was the case the district court relied on in ruling in this case and which the Ninth Circuit simply followed in affirming the district court in this case, was to look at the Federal income rules before looking at the question of whether the State has the discretion and the right to require AFD recipients who live together in the same household to be considered one assistance unit for purposes of computing the grant that they receive from the State.

In essence, the Ninth Circuit put the cart before the horse.

It looked at the income availability rules before looking at the State's discretion to decide that assistance units and groups of AFDC recipients living in the same household may be combined.

The rule that we are proposing that the Court adopt in this case is that under cooperative federalism, which this Court has recognized is the AFDC system that Congress has enacted, the States have the discretion to make this kind of a rule, that assistance units living in the same household be combined, a part of their AFDC program.

To put that another way, we're asking this Court to hold that neither Congress nor the Secretary of Health & Human Services have... by express edict, where that is the only way the State's discretion may be circumscribed in the AFDC programs, have taken that discretion away from the States.

I would like to illustrate first how the rule works in... with a practical example, and then I would like to make four points.

First of all, the points I would like... just briefly going through the points I would like to make this morning, first of all, deciding who must be in an AFDC assistance unit is largely a matter of State discretion, just as the State has a right to decide how poor a person has to be before they receive benefits and how much AFDC benefits the State should pay that person.

The second point, when assistance units are combined, the income and resources of all the persons in that household who are claiming AFDC are considered as available to every other member of that unit.

The availability rules really relate to the situation after the assistance units are combined, and determining whether the individual has income available to that person such that it then, because of the combination of the assistance units and the operation of the Federal statute--

Sandra Day O'Connor:

Does the rule only apply insofar as people in the household are asking for the Federal-State assistance to them?

In other words, suppose you had one member of any of the units involved here who won a big pile of money on a lottery ticket, could that person opt out of welfare benefits and the State couldn't force those who remained to consider that person's--

Dennis Paul Eckhart:

--Well, Your Honor... Your Honor's question--

Sandra Day O'Connor:


Dennis Paul Eckhart:

--Your question implicates the lump sum rule.

First of all, the answer to your question is that once the assistance unit is combined, the income and resources that are available to each of those individuals are considered available to the unit as a whole.

Sandra Day O'Connor:

Well, can someone opt out of the unit and say, I don't want assistance any more, so don't count me in?

Dennis Paul Eckhart:

Well, there are two answers to that.

First of all, Your Honor, there is a Federal family filing unit rule in section 602(a)(38) of 42 U.S.C. which provides that if the... where Congress provided in 1984 that the father, mother, and brothers and sisters, all of whom live in the same household, their needs and income must be considered together, such that if one of those individuals receives a lottery winning or a lump sum income of some kind, that person, that income is deemed available to all the individuals.

Sandra Day O'Connor:

Let's say it is not a father, mother, and their children.

We have these... a nephew or a cousin or something in the household.