## Facts

- Indiana participated in AFDC, a joint federal–state cash-assistance program administered by the state.
- In 1994, Indiana obtained federal approval under Social Security Act § 1115 to operate a welfare-reform demonstration project, including a “family cap” feature.
- The demonstration project used a “control group” that continued under prior AFDC rules and a “treatment group” subject to revised TANF rules, including the family cap.
- Under the family cap, a recipient family’s cash grant did not increase for a child born ten or more months after the family began receiving AFDC/TANF benefits, subject to limited exceptions (e.g., the child does not reside with the recipient parent).
- N.B., a recipient who had been receiving benefits for approximately three years and had two children, became pregnant with a third child despite using birth control.
- Because the third child was born ten or more months after benefits began, the State informed N.B. that her cash benefits would not increase after the child’s birth.
- N.B. and similarly situated recipients brought a certified class action against Indiana welfare officials, alleging the family-cap policy violated equal protection and substantive due process.
- The trial court granted summary judgment to the State; the class appealed.

## Issues

1. Whether Indiana’s TANF family-cap provision violates the Equal Protection Clause of the Fourteenth Amendment.
2. Whether the family-cap provision violates substantive due process by burdening reproductive choice.

## Decision

- The Indiana Court of Appeals affirmed summary judgment for the State.
- The court held the family-cap provision did not violate equal protection because it neither used a suspect classification nor burdened a fundamental right, and it was rationally related to legitimate governmental purposes.
- The court held the family-cap provision did not violate substantive due process because it did not directly regulate procreation and there is no fundamental right to increased welfare benefits for each additional child.
- The court concluded the § 1115 demonstration structure, including different treatment of control and treatment groups, was rationally related to evaluating welfare-reform measures.

## Legal Principles

- Welfare-benefit classifications that do not involve a suspect class or a fundamental right are reviewed under rational basis scrutiny.
- A state may limit incremental public-assistance benefits for children born after a family begins receiving assistance if the limitation is rationally related to legitimate governmental interests, including cost containment and encouraging self-sufficiency.
- The constitutional protection for decisions about childbearing does not create a fundamental entitlement to increased public subsidies; declining to increase benefits is not equivalent to a direct prohibition or coercive sanction on childbirth.
- Differential treatment between control and treatment groups in a federally approved demonstration project can be justified under rational basis review as a means of evaluating program effectiveness.

## Conclusion

The court upheld Indiana’s TANF family-cap rule, concluding that limiting benefit increases for later-born children in a § 1115 demonstration project was rationally related to legitimate welfare-reform objectives and did not violate equal protection or substantive due process.


N.B. v. Sybinski, 724 N.E.2d 1103 (Ind. Ct. App. 2000)