King v. Smith
392 U.S. 309 (1968)
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Rule of Law:
Under the Social Security Act, states participating in the Aid to Families with Dependent Children (AFDC) program cannot deny benefits to otherwise eligible children on the basis that their mother cohabits with a man who is not their biological or adoptive father and has no state-imposed legal duty to support them. The term 'parent' in the Act refers only to an individual with a legal obligation of support.
Facts:
- Mrs. Sylvester Smith and her four minor children received assistance under Alabama's Aid to Families With Dependent Children (AFDC) program.
- The children's fathers were either deceased or had been continually absent from the home, and the children were not receiving parental support.
- Alabama's Department of Pensions and Security enacted a 'substitute father' regulation, which terminated AFDC benefits if a child's mother cohabited with an able-bodied man, regardless of whether he was the children's father or legally obligated to support them.
- State officials terminated the Smith family's AFDC benefits on the ground that a Mr. Williams visited Mrs. Smith's home on weekends and had sexual relations with her.
- Mr. Williams was married and lived with his own wife and nine children, whom he supported.
- Mr. Williams was not the father of any of Mrs. Smith's children, was not legally obligated under Alabama law to support them, and did not in fact contribute to their support.
- Following the termination of benefits, the Smith family's sole income was Mrs. Smith's weekly salary of $16 to $20.
Procedural Posture:
- Mrs. Smith (appellee), on behalf of herself and her children, filed a class action lawsuit in the U.S. District Court for the Middle District of Alabama against state welfare officials (appellants).
- The suit sought an injunction and a declaratory judgment that Alabama's 'substitute father' regulation violated the Social Security Act and the Equal Protection Clause of the Fourteenth Amendment.
- A three-judge federal district court was convened to hear the case.
- The District Court held that the regulation was inconsistent with the Social Security Act and violated the Equal Protection Clause, and it enjoined the state from enforcing the regulation.
- The Alabama officials then filed a direct appeal to the Supreme Court of the United States.
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Issue:
Does Alabama's 'substitute father' regulation, which denies AFDC benefits to children whose mother cohabits with a man not legally obligated to support them, conflict with the definition of 'parent' under Section 406(a) of the Social Security Act?
Opinions:
Majority - Chief Justice Warren
Yes. Alabama's 'substitute father' regulation is invalid because it defines 'parent' in a manner inconsistent with the Social Security Act. The court reasoned that the central purpose of the AFDC program is to protect needy children who have been deprived of support from a parent. Congress intended the term 'parent' in Section 406(a) of the Act to mean an individual who owes the child a state-imposed legal duty of support. A man who is not a child's natural or adoptive father and has no legal obligation to support that child cannot be considered a 'parent' under the Act. Alabama's regulation created a fictional 'substitute father' whose presence terminated aid, even though he provided no actual or legal support, thereby punishing destitute children and undermining the Act's goal of providing for their economic security. The Court also rejected Alabama's justifications of discouraging immorality, noting that Congress had moved away from a 'worthy person' concept of welfare and toward rehabilitative measures that do not punish children for a parent's conduct.
Concurring - Justice Douglas
Yes. While agreeing with the outcome, Justice Douglas would have decided the case on constitutional grounds, finding that the regulation violates the Equal Protection Clause of the Fourteenth Amendment. He argued that the regulation invidiously discriminates against needy children by punishing them for the 'sin' of their mother. Just as the Court held in Levy v. Louisiana that it is unconstitutional to discriminate against illegitimate children, it is equally unconstitutional to deny children essential welfare benefits based on their mother's nonmarital sexual relations. He reasoned that the immorality of the mother has no rational connection to the economic needs of her children, making the classification arbitrary and discriminatory.
Analysis:
This landmark decision invalidated 'man-in-the-house' and 'substitute father' regulations used by many states to disqualify families from receiving AFDC benefits. The ruling established a crucial precedent that states participating in cooperative federalism programs like AFDC must adhere to the definitions and paramount objectives established by federal law. By defining 'parent' based on legal support obligations, the Court shifted the focus of eligibility from the mother's perceived morality to the child's actual economic need. This decision significantly limited states' ability to impose their own moral standards as conditions for welfare eligibility and reinforced the principle that the primary goal of the AFDC program is the protection of dependent children.
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