Facts of the Case
After Plaintiff Barbara James, an Aid to Families with Dependent Children (AFDC) recipient, refused to allow a caseworker to visit her in her home, her benefits were then terminated, as required by state statutes and policies governing the AFDC program. Argueing that the home visit was a search that violated her
Did New York violate James’ Fourth and Fourteenth Amendment rights in terminating her AFDC benefits when she refused the caseworker visit?
No. In a 6-3 opinion, the Court held that a caseworker visit was not a search under the Fourth Amendment. Writing for the majority, Justice Harry A. Blackmun reasoned that the visitation in itself is not forced or compelled, and as a result, there is no entry of the home and there is no search. Even if the caseworker visit does possess some of the characteristics of a search in the traditional sense, the visit still would not violate the Fourth Amendment, under the unreasonableness standard set forth in Terry v. Ohio . The Court concluded that the caseworker visit was not unreasonable, as the visit allowed the state to focus on the child and to ensure that its welfare funds were being used properly. Moreover, the visit was not confrontational and James’ refusal did not lead to criminal prosecution. Justice Byron R. White concurred in the judgment.
- Citation: 400 US 309 (1971)
- Argued: Oct 20, 1970
- Decided Jan 12, 1971