## Facts

- The Aid to Families with Dependent Children (AFDC) program provided federal matching funds to participating states, conditioned on state administration consistent with federal statutory eligibility terms.
- Federal law defined a “dependent child” as a needy child deprived of parental support or care due to death, continued absence, or incapacity of a parent, and living with specified relatives.
- Alabama adopted a “substitute father” regulation denying AFDC to children if their mother “cohabited” with an able-bodied man, treating that man as a non-absent “parent” even if he was not the children’s father and had no duty to support them.
- Sylvester Smith and her four children had received AFDC for years; benefits were terminated solely because an adult man visited on weekends and had sexual relations with Smith.
- The man was not the father of any child, had no state-law support obligation to them, and did not support them.
- Smith filed a § 1983 class action in federal court seeking declaratory and injunctive relief against enforcement of the regulation.
- A three-judge district court held the regulation inconsistent with the Social Security Act and the Equal Protection Clause; state officials appealed directly to the U.S. Supreme Court.

## Issues

1. Whether Alabama’s “substitute father” regulation conflicted with the Social Security Act’s AFDC eligibility definitions by treating a cohabiting man without a legal duty of support as a “parent” and thereby denying aid to otherwise eligible children.
2. Whether the regulation violated the Equal Protection Clause of the Fourteenth Amendment (if the case could not be resolved on statutory grounds).

## Decision

- The Supreme Court unanimously affirmed the judgment invalidating Alabama’s substitute father regulation.
- The Court held the regulation inconsistent with the Social Security Act because it redefined “parent” to include a man with no legal obligation to support the children.
- The Court concluded the state rule effectively imposed an additional, unauthorized condition of AFDC eligibility.
- The Court resolved the case on statutory grounds and did not reach the Equal Protection question.

## Legal Principles

- In cooperative federal-state benefit programs, participating states must administer assistance in conformity with federal statutory eligibility criteria and may not add inconsistent disqualifications.
- For AFDC eligibility, “parent” refers to a person with a legal duty of support under state law; a “substitute father” without legal parental status or support obligation is not a “parent” for purposes of the federal definition of “dependent child.”
- A state may not deny AFDC benefits to children who meet federal eligibility standards based solely on the mother’s nonmarital relationship with a man lacking legal responsibility for the children.
- When a state rule conflicts with controlling federal statutory definitions and purposes, it is invalid under federal supremacy; courts may decide the case on statutory grounds without addressing constitutional claims.

## Conclusion

The Court invalidated Alabama’s substitute father regulation because it conflicted with federal AFDC eligibility definitions by treating a non-legally responsible cohabiting man as a “parent,” thereby denying aid to children Congress intended the program to protect.


King v. Smith, 392 U.S. 309 (1968)