Dandridge v. Williams

Brief Fact Summary.

The petitioner challenged the method used by Maryland, in the administration of an aspect of its public welfare program, to reconcile the demands of its needy citizens with the finite resources available to meet those demands. Maryland participates in the Federal Aid to Families with Dependent Children (AFDC) program, just like every other State.

Synopsis of Rule of Law.

A regulation can be clearly justified in terms of legitimate state interests in encouraging gainful employment, in maintaining an equitable balance in economic status as between welfare families and those supported by a wage-earner, in providing incentives for family planning and in allocating available public funds in such a way as to meet the needs of the largest possible number of families.

Facts.

Maryland computes the standard of need for each eligible family based on the number of children in the family and the circumstances under which the family lives. Generally, the standard of need increases with each additional person in the household, but the increments become proportionately smaller. The regulation at issue imposes upon the grant that any single family may receive an upper limit of $250 per month in certain counties. The appellees have large families, so that their standards of need as computed by the State substantially exceed the maximum grants that they actually receive under the regulation. The appellees contended that the maximum grant limitation operates to discriminate against them merely because of their size of their families in violation of the Equal Protection Clause of the Fourteenth Amendment.

Issue.

Does the Maryland’s practice of computing the standard of need for each eligible family based on the number of children in the family and the circumstances under which the family lives violate the Equal Protection Clause of the Fourteenth Amendment?

Held.

No, under the long-established meaning of the Equal Protection Clause, the Maryland maximum grant regulation is constitutionally valid. A solid foundation for the regulation can be found in the State’s legitimate interest in encouraging employment and in avoiding discrimination between welfare families and the families of the working poor. By combining a limit on the recipient’s grant with permission to retain money earned, without reduction in the amount of the grant, Maryland provides an incentive to seek gainful employment.

Discussion.

It is true that in some AFDC families there may be no person who is employable and with respect to AFDC families whose determined standard of need is below the regulatory maximum and who therefore receive grants equal to the determined standard, the employment incentive is absent. However, the Equal Protection Clause does not require that a State must choose between attacking every aspect of a problem or not attacking a problem at all. It is sufficient that the State’s action be rationally based and free from invidious discrimination. The regulation at issue meets this test. Moreover, it is not the Court’s role to determine that the Maryland regulation is wise or it best fulfills the relevant social and economic objectives that Maryland might ideally espouse. Conflicting claims of morality and intelligence are raised by proponents and opponents of almost every measure. But the intractable business, economic or social problems presented by public welfare assistance programs are not the business of the Court but that of the legislatures.