Appellant
Edmund P. Dandridge, Jr., et al.
Appellee
Linda Williams et al.
Appellant's Claim
That the Maryland maximum grant regulation was in conflict with the Federal Social Security Act and with equal protection under the Fourteenth Amendment.
Chief Lawyer for Appellant
George W. Liebmann
Chief Lawyer for Appellee
Joseph A. Matera
Justices for the Court
Hugo Lafayette Black, Warren E. Burger, John Marshall Harlan II, Potter Stewart (writing for the Court), Byron R. White
Justices Dissenting
William J. Brennan, Jr., William O. Douglas, Thurgood Marshall (Harry A. Blackmun had not yet been appointed to the Court)
Place
Washington, D.C.
Date of Decision
6 April 1970
Decision
The Supreme Court held that the regulation does not violate the Equal Protection Clause and reversed the lower court's decision.
Significance
The states have the right to regulate the absolute amount of aid received bya family regardless of size or determined need and the regulation was not inconsistent with the Social Security Act nor violative of the Equal ProtectionClause.
In connection with its participation in the Federal Aid to Families with Dependent Children program, the state of Maryland imposed, through administrativeregulation, a maximum limit on the total amount of aid which any one familyunit could receive. The appellants, who had large families, and whose standards of need as computed by the state substantially exceeded the maximum amountof aid which they received under the regulation, brought suit in the U.S. District Court for the District of Maryland. They argued that Maryland's maximum grant regulation was in conflict with the Federal Social Security Act. Theappellants also argued that the regulation violated their equal protection rights under the Fourteenth Amendment.
A three-judge District Court was convened and held that the regulation violated the Equal Protection Clause of the Fourteenth Amendment. The case then went to the Supreme Court.
The Supreme Court reversed the decision of the lower court. In an opinion written by Justice Stewart, expressing the views of five members of the court, it was held that the maximum-grant regulation was not inconsistent with the Social Security Act and did not violate the Equal Protection Clause of the Fourteenth Amendment.
Justices Black and Burger concurred with the decision. They relied upon the Secretary of Health, Education, and Welfare's determination that the regulation was consistent with the Social Security Act.
In a dissenting opinion, Justice Douglas said that the maximum-grant regulation was inconsistent with the terms and purposes of the Social Security Act. Douglas added that he would not find it necessary to decide upon the equal protection issue. Justices Marshall and Brennan also held that the maximum-grantregulation was inconsistent with the Social Security Act, but added that such regulation was invalid under the Equal Protection Clause of the FourteenthAmendment.
Related Cases
Welfare Regulation
Public welfare assistance programs for the nation's poor have been controversial since before the 1930s Great Depression era, when they were largely operated by state and local governments. Guided by ideals of individualism and self-reliance, welfare benefits are commonly viewed as a privilege, not a right.With rapid expansion of the federal welfare system following passage of theSocial Security Act in 1935, many grew to consider welfare benefits to be entitlements.
Under extensive federal oversight, states attempted to locally regulate welfare programs in the 1950s and 1960s through residency requirements, illegitimate children restrictions, and other means. Such efforts were routinely deemedin violation of federal equal protection guarantees. By the 1970s, states were required to provide food stamp and Medicaid programs but were free to determine recipients' eligibility. Similarly, federal public housing programs consistently relied on local administration. In the 1980s, states began to assume greater freedom to enforce work requirements on welfare recipients.
The 1996 Personal Responsibility and Work Opportunity Reconciliation Act, better known as the Welfare Reform Act, more fully returned regulation of welfare programs to state and local governments. With limited financial resources,states developed new welfare plans under substantially less federal oversightto meet the demands of their needy citizens.
Sources
Wolch, Jennifer R. "America's New Urban Policy: Welfare Reform and the Fate of American Cities," Journal of the American Planning Association. Winter 1998.
Edmund P. Dandridge, Jr., et al.
Appellee
Linda Williams et al.
Appellant's Claim
That the Maryland maximum grant regulation was in conflict with the Federal Social Security Act and with equal protection under the Fourteenth Amendment.
Chief Lawyer for Appellant
George W. Liebmann
Chief Lawyer for Appellee
Joseph A. Matera
Justices for the Court
Hugo Lafayette Black, Warren E. Burger, John Marshall Harlan II, Potter Stewart (writing for the Court), Byron R. White
Justices Dissenting
William J. Brennan, Jr., William O. Douglas, Thurgood Marshall (Harry A. Blackmun had not yet been appointed to the Court)
Place
Washington, D.C.
Date of Decision
6 April 1970
Decision
The Supreme Court held that the regulation does not violate the Equal Protection Clause and reversed the lower court's decision.
Significance
The states have the right to regulate the absolute amount of aid received bya family regardless of size or determined need and the regulation was not inconsistent with the Social Security Act nor violative of the Equal ProtectionClause.
In connection with its participation in the Federal Aid to Families with Dependent Children program, the state of Maryland imposed, through administrativeregulation, a maximum limit on the total amount of aid which any one familyunit could receive. The appellants, who had large families, and whose standards of need as computed by the state substantially exceeded the maximum amountof aid which they received under the regulation, brought suit in the U.S. District Court for the District of Maryland. They argued that Maryland's maximum grant regulation was in conflict with the Federal Social Security Act. Theappellants also argued that the regulation violated their equal protection rights under the Fourteenth Amendment.
A three-judge District Court was convened and held that the regulation violated the Equal Protection Clause of the Fourteenth Amendment. The case then went to the Supreme Court.
The Supreme Court reversed the decision of the lower court. In an opinion written by Justice Stewart, expressing the views of five members of the court, it was held that the maximum-grant regulation was not inconsistent with the Social Security Act and did not violate the Equal Protection Clause of the Fourteenth Amendment.
Justices Black and Burger concurred with the decision. They relied upon the Secretary of Health, Education, and Welfare's determination that the regulation was consistent with the Social Security Act.
In a dissenting opinion, Justice Douglas said that the maximum-grant regulation was inconsistent with the terms and purposes of the Social Security Act. Douglas added that he would not find it necessary to decide upon the equal protection issue. Justices Marshall and Brennan also held that the maximum-grantregulation was inconsistent with the Social Security Act, but added that such regulation was invalid under the Equal Protection Clause of the FourteenthAmendment.
Related Cases
- Graham v. Richardson, 403 U.S. 365 (1971).
- San Antonio Independent School District, et al. v. Demetrio P. Rodriguez, et al., 411 U.S. 1 (1973).
- Gurley v. Wohlgemuth, 421 F.Supp. 1337 (1976).
- Joyner v. Dumpson, 533 F.Supp. 233 (1982).
- Daugherty v. Wallace, 621 N.E. 2d 1374 (1993).
Welfare Regulation
Public welfare assistance programs for the nation's poor have been controversial since before the 1930s Great Depression era, when they were largely operated by state and local governments. Guided by ideals of individualism and self-reliance, welfare benefits are commonly viewed as a privilege, not a right.With rapid expansion of the federal welfare system following passage of theSocial Security Act in 1935, many grew to consider welfare benefits to be entitlements.
Under extensive federal oversight, states attempted to locally regulate welfare programs in the 1950s and 1960s through residency requirements, illegitimate children restrictions, and other means. Such efforts were routinely deemedin violation of federal equal protection guarantees. By the 1970s, states were required to provide food stamp and Medicaid programs but were free to determine recipients' eligibility. Similarly, federal public housing programs consistently relied on local administration. In the 1980s, states began to assume greater freedom to enforce work requirements on welfare recipients.
The 1996 Personal Responsibility and Work Opportunity Reconciliation Act, better known as the Welfare Reform Act, more fully returned regulation of welfare programs to state and local governments. With limited financial resources,states developed new welfare plans under substantially less federal oversightto meet the demands of their needy citizens.
Sources
Wolch, Jennifer R. "America's New Urban Policy: Welfare Reform and the Fate of American Cities," Journal of the American Planning Association. Winter 1998.
Further Readings
- Biskupic, Joan, and Elder Witt, eds. Congressional Quarterly's Guide to the U.S. Supreme Court, 3rd ed. Washington, DC: Congressional Quarterly, Inc., 1996.
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