Maine v. Thiboutot

LOCATION: Congress

DOCKET NO.: 79-838
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: Maine Supreme Judicial Court

CITATION: 448 US 1 (1980)
ARGUED: Apr 22, 1980
DECIDED: Jun 25, 1980

James Eastman Smith - on behalf of the Petitioners
Robert Edmond Mittle - for respondents
Robert Edmond Mittel - on behalf of Respondents

Facts of the case


Media for Maine v. Thiboutot

Audio Transcription for Oral Argument - April 22, 1980 (Part 2) in Maine v. Thiboutot

Audio Transcription for Oral Argument - April 22, 1980 (Part 1) in Maine v. Thiboutot

Warren E. Burger:

We will now hear arguments in the State of Maine v Thiboutot.

Mr. Smith, I think you may proceed whenever you are ready.

James Eastman Smith:

Thank you, Mr. Chief Justice.

Mr. Chief Justice, and may it please the Court.

A Writ of Certiorari was granted to the Maine Supreme Judicial Court on January 21, 1980, in the above matter.

Questions presented therein were threefold.

First, whether the Petitioners' good faith violation of the Federal Social Security Act and its regulations, with the resulting incorrect reduction of AFDC benefits to the Respondents, but without a violation of Respondents' constitutional rights, constitutes a violation of 42 USC Section 1983.

The second question posed was whether the Civil Rights Act of 1976, 42 USC Section 1988, allows consideration of an award of attorney's fees to Respondents who prevail solely on a Social Security Act claim in an Action where no violation of constitutional rights is found.

The final question was whether or not 42 USC Section 1983 affords Respondents a remedy in the State Court for a violation of the Social Security Act.

The statement of the facts follows.

The Respondents, Lionel and Joline Thiboutot, are married and have eight children.

Four of those children are theirs pursuant to their common marriage.

Three of the children were brought into the common marriage pursuant to a prior marriage of Mr. Thiboutot's.

One child was Mrs. Thiboutot's pursuant to a prior marriage.

In November of 1975, the State of Maine, Department of Human Services, reduced, or notified Mr. Thiboutot they were going to reduce, his benefits pursuant to a change in what we believe, deemed by Federal Regulations.

They notified him of this proposed change.

The change was as follows.

In computing the net available income of Mr. Thiboutot, in order to determine the amount of AFDC benefits to be allowed for his three children by a prior marriage, the Department would no longer subtract that portion of Mr. Thiboutot's income which went to the support of the four children by the common marriage.

The effect of this was to count as available, in the computation of the eligibility benefits, income which was actually unavailable due to Mr. Thiboutot's legal obligation to support his four mutual children.

After exhausting their administrative remedies, the Thiboutots, pursuant to a complaint filed in Superior Court, appealed the Department's decision and on their computation basis.

This appeal was brought originally pursuant to Maine Rules of Civil Procedure, Rule 80B, and two statutes which in and of themselves allow for the Maine State Courts to take jurisdiction of cases such as this the denial or a reduction of AFDC benefits.

On January 7, 1977, an amended complaint was filed in the same Court.

This followed the enactment of the Civil Rights Attorneys Fees Act of 1976.

The amended complaint brought pursuant to 1983, as well as the other State Statutes which would have allowed jurisdiction in the State as well as the cause of action, alleged violation of the Social Security Act, regulations pertaining to the Social Security Act, and also asked for certification as a class action which was granted.

The Maine Superior Court entered judgment for the Thiboutots on the merits.

The Petitioners were enjoined from enforcing the challenged regulations; and in compliance with Court Order, adopted new regulations.

The State also paid benefits, respectively, to all class members who were eligible; and also paid retroactive benefits to the Thiboutots.

However, another issue is still before the Court, and that issue is attorney's fees.

The Court in subsequent motion denied the Respondents' plea for attorney's fees, which was then appealed to the Supreme Judicial Court for the State of Maine.

Warren E. Burger:

What other issues are here now, other than attorney's fees?