Dandridge v. Williams, 397 U.S. 471 (1970)

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

  1. 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.
  2. 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.
  • 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.