Dandridge v. Williams
397 U.S. 471 (1970)
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Rule of Law:
A state regulation in the area of economic and social welfare that imposes a maximum grant on welfare benefits does not violate the Equal Protection Clause so long as the classification has a rational basis. Such regulations are not subject to a heightened level of judicial scrutiny, as states have broad latitude in allocating public welfare resources.
Facts:
- Maryland participates in the federal Aid to Families with Dependent Children (AFDC) program, a jointly financed public welfare initiative.
- The state calculates a 'standard of need' for each eligible family, with the standard generally increasing as the number of family members increases.
- Maryland implemented a 'maximum grant regulation,' which imposed an upper limit on the total monthly grant any single family could receive, set at $250 in certain counties and $240 elsewhere.
- The appellees, including a woman named Williams, are recipients of AFDC benefits and have large families.
- Due to their family size, the appellees' calculated 'standard of need' substantially exceeded the maximum grant they were eligible to receive under the regulation.
- The practical effect of the regulation was that children in larger families received a smaller per capita benefit than children in smaller families whose needs were fully met.
Procedural Posture:
- Several AFDC recipients sued Maryland state officials in the United States District Court to enjoin the enforcement of the state's maximum grant regulation.
- A three-judge District Court was convened to hear the case.
- The District Court held that the Maryland regulation was invalid because it violated the Equal Protection Clause of the Fourteenth Amendment.
- Maryland state officials (appellants) filed a direct appeal to the Supreme Court of the United States.
- The Supreme Court noted probable jurisdiction to hear the case.
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Issue:
Does Maryland's maximum grant regulation, which caps the total amount of Aid to Families with Dependent Children (AFDC) benefits a family can receive regardless of its size, violate the Equal Protection Clause of the Fourteenth Amendment by creating a discriminatory classification based on family size?
Opinions:
Majority - Justice Stewart
No, Maryland's maximum grant regulation does not violate the Equal Protection Clause of the Fourteenth Amendment. State regulations in the social and economic field are constitutional if they have a rational basis. The Court first addressed the statutory claim, finding the regulation permissible under the Social Security Act. The Act gives states 'great latitude' and 'considerable latitude in allocating their AFDC resources,' and a 1967 amendment explicitly recognized the existence of state-imposed maximums. On the constitutional question, the Court held that welfare administration falls into the category of 'economics and social welfare,' where the rational basis test applies, not strict scrutiny. The regulation is rationally supported by the State's legitimate interests in encouraging employment, maintaining an equitable balance between welfare families and the working poor, and allocating limited public funds to the largest possible number of families. It is not the Court's role to second-guess the wisdom or fairness of state social policies.
Concurring - Justice Black
Joins the Court's opinion but expresses doubt, consistent with his dissent in Rosado v. Wyman, that individual welfare recipients should be able to sue state authorities over a welfare plan that the Secretary of Health, Education, and Welfare (HEW) has already approved as consistent with federal law.
Concurring - Justice Harlan
Joins the Court's opinion but rejects the two-tiered approach to equal protection analysis (rational basis vs. compelling interest). He believes a single standard of rationality should apply to all classifications except those based on race. He concurs because the Maryland regulation satisfies this standard of rationality, not merely because it involves 'economics and social welfare.'
Dissenting - Justice Douglas
Yes, the regulation should be invalidated on statutory grounds, making it unnecessary to reach the constitutional question. The Maryland regulation is inconsistent with the Social Security Act. The Act's mandate to provide aid to 'all eligible individuals' applies to each dependent child, not just the family unit. The regulation effectively denies benefits to children in large families who are otherwise eligible. Furthermore, the regulation creates a 'powerful economic incentive to break up large families' by encouraging parents to place 'excess' children with relatives to receive separate aid, which directly contradicts the Act’s core purpose of strengthening family life.
Dissenting - Justice Marshall
Yes, the regulation violates both the Social Security Act and the Equal Protection Clause. On statutory grounds, it arbitrarily denies aid to a class of eligible children and creates an incentive for family disintegration. Constitutionally, the majority's application of a deferential rational basis test is inappropriate for a case involving 'the most basic economic needs of impoverished human beings.' The classification based on family size is arbitrary and denies equal treatment to similarly situated needy children. The state's asserted justifications, like promoting employment, are not rationally served by a regulation that is both overinclusive (applying to unemployable parents) and underinclusive (applying only to large families).
Analysis:
This landmark decision solidified the Supreme Court's two-tiered approach to Equal Protection analysis, establishing that social and economic welfare classifications are subject only to the highly deferential rational basis test. By refusing to apply strict scrutiny to a classification affecting subsistence benefits, the Court granted states immense discretion in designing and administering welfare programs, even if those programs result in unequal treatment among recipients. The ruling significantly limited the scope of judicial intervention in poverty law, making it much more difficult for litigants to challenge welfare regulations on constitutional grounds unless they could show discrimination based on a suspect class like race.
