Dandridge v. Williams, 397 U.S. 471

Supreme Court of the United States

1970

Chapter

6

Title

Implied Fundamental Rights

Page

814

Topic

Economic and social welfare statutes call only for mere Rational Basis review.

Quick Notes

Large families, in Maryland, challenge a federal aid program, Families with Dependent Children (AFDC), which resulted in a disparity in aid between large families and small families.  The maximum monthly grant regardless of family size was $250 per family.

Rule

o         Disparities in welfare benefits offered to qualifying beneficiaries need only be supported by a rational basis.

Justice Stewart - Over and Under Inclusive

o         The equal protection clause does not require that a State must choose between attacking every aspect of a problem or not attacking the problem at all.

o         It is enough that the States action be rationally based and free from invidious discrimination.

Rational Basis

o         The disparity between large and small family aid, under the program, is supported by a rational basis that is consistent with legitimate state objectives.

Statute involves economic and social welfare

o         A state need only provide a rational basis for the statute because it involves economic and social welfare.

Encourages employment and avoids discrimination

o         Maryland expressed a legitimate interest in encouraging employment and in avoiding discrimination between welfare families and the families of the working poor.

Dissent - Justice Marshall

o         This case involved the VITAL interests of a powerless minority, the poor families, without breadwinners.

o         This minority is far removed from the area of business regulation.

Equal Protection Analysis should concentrate on

1.     The character of the classification in question.

2.     The relative importance to the individuals in the class discriminated against of the government benefits that they do not receive

3.     The asserted state interests in support of the classification.

Book Name

Constitutional Law : Stone, Seidman, Sunstein, Tushnet.  ISBN:  978-0-7355-7719-0

Issue

o         Whether a federal aid program that contains a maximum grant provision is unconstitutional because it results in a disparity in aid between large and small families?   No.  But see Justice Marshalls Dissent.

Procedure

Trial

o         United States District Court for the District of Maryland holding that its Aid to Families With Dependent Children (AFDC) statute, which contained a "maximum grant" provision, violated the Equal Protection Clause of U.S. Const. amend. XIV.

Supreme

o         Reversed.

o         The court also held that the "maximum grant" provision did not violate the Equal Protection Clause because the classification had a reasonable basis in promoting the State's interest in encouraging employment and avoiding invidious discrimination between welfare families and families of the working poor.

Facts/Cases

Discussion

Key Phrases

Rules/Laws

Pl -   Dandridge

Df -   Williams

Description

o         Large families, in Maryland, challenge a federal aid program, Families with Dependent Children (AFDC), which resulted in a disparity in aid between large families and small families.

o         The maximum monthly grant regardless of family size was $250 per family.

Justice Stewart

o         Dealing with state regulation in the social and economic field, not affecting freedoms guaranteed by the Bill of Rights.

Economic and Social Welfare

o         A State does not violate the Equal Protection Clause merely because the classifications made by its law are imperfect.

Reasonable Basis

o         If the classification has some reasonable Basis, it does not offend he Constitution.

Grant is Constitutionally Valid

o         By keying the maximum family AFDC grants to the minimum wage a steadily employed head of house received, the regulation encourages employment and avoids discrimination between welfare families and the families of the working poor.

Over and Under Inclusive

o         The equal protection clause does not require that a State must choose between attacking every aspect of a problem or not attacking the problem at all.

o         It is enough that the States action be rationally based and free from invidious discrimination.

Dissent - Justice Marshall

o         This case involved the VITAL interests of a powerless minority, the poor families, without breadwinners.

o         This minority is far removed from the area of business regulation.

Equal Protection Analysis should concentrate on

1.     The character of the classification in question.

2.     The relative importance to the individuals in the class discriminated against of the government benefits that they do not receive

3.     The asserted state interests in support of the classification.

Individual Interest are at stake

o         It is the individual interests here at stake that, as the Court concedes, most clearly distinguish this case from the "business regulation" equal protection cases.

o         AFDC support to needy dependent children provides the stuff that sustains those children's lives: food, clothing, shelter.

o         And this Court has already recognized several times that when a benefit, even a "gratuitous" benefit, is necessary to sustain life, stricter constitutional standards, both procedural and substantive, are applied to the deprivation of that benefit.

They are needy children

o         Appellees are not a gas company or an optical dispenser; they are needy dependent children and families who are discriminated against by the State.

The discrimination is not rationale

o         The basis of that discrimination

1.     -- the classification of individuals into large and small families

2.     -- is too arbitrary and too unconnected to the asserted rationale, the impact on those discriminated against

3.     -- the denial of even a subsistence existence -- too great, and the supposed interests served too contrived and attenuated to meet the requirements of the Constitution

Rules

Rule

o         Disparities in welfare benefits offered to qualifying beneficiaries need only be supported by a rational basis.

Class Notes