Facts
- Aid to Families with Dependent Children (AFDC) was a joint federal–state program in which states calculated a “standard of need” for eligible families.
- Maryland’s regulations increased the standard of need with family size but used decreasing per-person increments as family size grew.
- Maryland also imposed a maximum monthly family grant (about $250), regardless of family size or the full measured need.
- The cap caused large AFDC families to receive less per person than smaller families whose grants were not capped.
- AFDC recipients in large families sued state welfare officials, alleging the cap conflicted with the Social Security Act and discriminated against large families in violation of the Fourteenth Amendment.
Issues
- Whether Maryland’s AFDC maximum-grant regulation was prohibited by the Social Security Act, including the requirement that aid be furnished with reasonable promptness to all eligible individuals.
- Whether the maximum-grant cap, which reduced per-capita assistance for larger families, denied equal protection under the Fourteenth Amendment.
Decision
- The Supreme Court reversed the three-judge district court.
- The Court held the maximum-grant regulation was not barred by the Social Security Act.
- The Court held the regulation did not violate Equal Protection because it was rationally supportable and not invidiously discriminatory.
- The Court applied deferential review appropriate to economic and social welfare policy and rejected the district court’s “overbreadth” rationale as inapplicable outside contexts such as the First Amendment.
Legal Principles
- In economic and social welfare regulation, equal-protection review generally asks only whether the classification has a rational basis and is not invidiously discriminatory.
- A state participating in a cooperative federal–state welfare program has broad discretion to allocate limited funds and set benefit levels within statutory bounds.
- A maximum-grant cap that reduces the overall family grant, without excluding otherwise eligible recipients from assistance, can be consistent with federal welfare statutes.
- Administrative approval by the responsible federal agency may support the conclusion that a state plan is compatible with federal statutory requirements.
- Equal protection does not require a state to address every aspect of a social problem completely as a condition of addressing any part of it.
Conclusion
The Court upheld Maryland’s AFDC maximum-grant cap, concluding that federal law allowed states substantial discretion in benefit design and that the resulting disparity in per-capita payments to larger families survived rational-basis review under the Equal Protection Clause.