Why is the case important?
Large families, in Maryland, challenge a federal aid program, which resulted in a disparity in aid between large families and small families.
Facts of the case
“The Aid to Families with Dependent Children (AFDC) program, established by the Social Security Act of 1935 and jointly funded by the state and federal governments, provides financial assistance to children of families with little or no income. Under the program, each state computes a “”standard of need”” for each family. In Maryland, the standard of need increased with each additional member of the family, but became incrementally smaller, with an upper limit of $250 per month. Linda Williams, a single mother, and Junius and Jeanette Gary, husband and wife, were Baltimore residents and parents of eight children each. They objected to Maryland’s means of calculating standard of need on the ground that it discriminated against larger families, in violation of the Equal Protection Clause. They also argued that the calculation conflicted with the stated purpose of the program as laid out by the Social Security Act. They filed suit against Edmund P. Dandridge, Chairman of the Maryland State Board of Public Welfare, and several other state officials. A U.S. District Court originally ruled the Maryland regulation violated both the Social Security Act and the Equal Protection Clause. On reconsideration, the court altered its ruling and based its judgment entirely on constitutional grounds but nonetheless struck down the provision.”
Whether a federal aid program is unconstitutional because it results in a disparity in aid between large and small families.
Justice Potter Stewart (J. Stewart). No. The federal aid program does not affect freedoms guaranteed by the Bill of Rights. The disparity between large and small family aid, under the program, is supported by a rational basis that is consistent with legitimate state objectives. The judgment of the lower court is reversed.
A state need only provide a rational basis for the statute because it involves economic and social welfare.
The statute is supported by a rational basis for the disparity in aid between large and small families. Maryland expressed a legitimate interest in encouraging employment and in avoiding discrimination between welfare families and the families of the working poor.
“The maximum grant provision did not violate § 602(a)(10) , which required that aid be furnished with reasonable promptness “”to all eligible individuals.”” The Social Security Act did not require that the aid furnished must equal the total of each individual’s standard of need in every family group, but only that some aid was provided to all eligible families and all eligible children. The court also held that the “”maximum grant”” provision did not violate the Equal Protection Clause because the classification had a reasonable basis in promoting the State’s interest in encouraging employment and avoiding invidious discrimination between welfare families and families of the working poor.”
- Case Brief: 1970
- Appellant: Edmund P. Dandridge, Chairman of the Maryland State Board of Public Welfare
- Appellee: Linda Williams et al.
- Decided by: Burger Court
Citation: 397 US 471 (1970)
Argued: Dec 9, 1969
Decided: Apr 6, 1970