## Facts

- Arizona operated a federally funded child support enforcement program under Title IV-D of the Social Security Act, subject to federal plan approval and oversight.
- Five Arizona custodial mothers applied for Title IV-D child support services and alleged they cooperated in good faith.
- They claimed the state agency failed to take adequate steps to establish paternity, locate absent parents, and obtain child support payments.
- They attributed the failures to staff shortages and structural problems in the statewide program.
- They sued the state official administering the program under 42 U.S.C. § 1983, seeking a declaration and an injunction requiring the State to bring its program into “substantial compliance” with Title IV-D across all operations.

## Issues

1. Whether Title IV-D creates an enforceable federal “individual right” under 42 U.S.C. § 1983 to compel a state agency’s “substantial compliance” with Title IV-D as a whole.
2. Whether Title IV-D’s administrative oversight mechanisms (federal audits and funding sanctions) foreclose § 1983 enforcement.

## Decision

- The Supreme Court vacated the judgment that recognized an enforceable right to statewide “substantial compliance” and remanded.
- Title IV-D does not give individuals a federal right to force a state agency to “substantially comply” with Title IV-D in general.
- The Court held the statute cannot be analyzed in the aggregate for § 1983 purposes; plaintiffs must identify specific statutory provisions that create individual rights.
- The Court rejected the view that federal administrative enforcement automatically bars all § 1983 suits, but required a provision-by-provision inquiry into enforceable rights and any congressional intent to preclude § 1983 remedies.

## Legal Principles

- § 1983 provides a remedy only for the violation of a federal right, not merely for noncompliance with federal law.
- A statutory provision creates an individually enforceable right only if: (1) the plaintiff is an intended beneficiary, (2) the asserted interest is not “vague and amorphous,” and (3) the provision imposes a binding obligation in mandatory terms.
- If a provision creates an enforceable right, there is a rebuttable presumption it is enforceable under § 1983.
- That presumption may be overcome if Congress expressly or impliedly foreclosed § 1983 by creating a remedial scheme incompatible with private enforcement.
- General programmatic standards such as statewide “substantial compliance” are insufficient, standing alone, to constitute judicially enforceable individual rights.

## Conclusion

The Court held that Title IV-D does not confer a freestanding § 1983 right to compel a State’s overall “substantial compliance” with child support program requirements, and required courts to assess any asserted § 1983 claim by identifying and evaluating specific rights-creating statutory provisions and any congressional intent to preclude private enforcement.


Blessing v. Freestone, 520 U.S. 329 (1997)