## Facts

- Pennsylvania amended its Public Welfare Code to change eligibility for state-funded general assistance from year-round benefits for all eligible recipients to a tiered system.
- The amendment created two categories: “chronically needy,” eligible for year-round benefits, and “transitionally needy,” limited to three months of benefits in any twelve-month period.
- “Chronically needy” status applied to otherwise eligible persons who fit enumerated categories, including children under 18 (or certain students), persons over age 45, and persons with serious physical or mental handicaps preventing substantial gainful activity.
- Otherwise eligible individuals who did not fit a “chronically needy” category—often able-bodied adults ages 18 to 45 without special-need status—were classified as “transitionally needy” and subject to the three-month cap.
- Plaintiffs, representing transitionally needy recipients (or would-be recipients), challenged the amendment as impermissible age discrimination under the Fourteenth Amendment’s Equal Protection Clause.
- The district court permanently enjoined enforcement of the amendment, holding the age-based classification unconstitutional.
- On appeal, plaintiffs conceded the Eleventh Amendment barred the suit against the Pennsylvania Department of Public Welfare, leaving the Secretary of Public Welfare as the operative defendant in his official capacity.

## Issues

1. Whether Pennsylvania’s age-linked classification of general assistance recipients (including year-round benefits for persons over 45 and limited benefits for many persons ages 18–45) violates the Equal Protection Clause.
2. What level of scrutiny applies to age-based classifications in a state public assistance program.
3. Whether the state agency defendant must be dismissed under the Eleventh Amendment.

## Decision

- The Third Circuit reversed the district court’s judgment and vacated the permanent injunction.
- The court held the statute did not violate equal protection because the age-based categories had a rational relationship to legitimate state interests.
- The court applied rational basis review, holding that age is not a suspect or quasi-suspect classification and public assistance recipients are not a suspect class.
- The court directed that the Pennsylvania Department of Public Welfare be dismissed as a defendant due to Eleventh Amendment immunity.

## Legal Principles

- Age-based classifications in social and economic legislation are reviewed under rational basis scrutiny unless they burden a fundamental right or target a suspect class.
- Under rational basis review, a classification is constitutional if any reasonably conceivable set of facts could provide a rational basis linking the classification to legitimate governmental objectives.
- A state may pursue fiscal integrity and targeted allocation of limited welfare resources as legitimate interests, including prioritizing benefits for groups the legislature could rationally view as less able to achieve self-support.
- In welfare programs, legislative line-drawing (including selection of an age cutoff) need not be precise or optimally calibrated to survive equal protection review.
- The Eleventh Amendment bars suits against state agencies in federal court absent consent or valid abrogation; claims for prospective relief may proceed against an appropriate state official in an official capacity.

## Conclusion

The Third Circuit upheld Pennsylvania’s revised general assistance eligibility scheme, concluding that limiting benefits for many 18–45-year-old recipients while granting year-round benefits to persons over 45 and other specified groups was rationally related to legitimate goals such as conserving scarce funds, prioritizing those less able to work, and encouraging self-support among employable adults; it also required dismissal of the state agency under the Eleventh Amendment.


Price v. Cohen, 715 F.2d 87 (3d Cir. 1983)