Dandridge v. Williams

Citation. 397 U.S. 471, 90 S.Ct. 1153, 25 L.Ed.2d 491 (1970).

Brief Fact Summary.

Plaintiffs brought suit challenging the upper limits of aid a family could receive, arguing they received less aid per child than smaller families in violation of the Equal Protection Clause of the 14th Amendment.

Synopsis of Rule of Law.

Welfare benefit disparities need only be supported by a rational basis.

Facts.

Maryland participated in the federal Aid to Families with Dependent Children program (AFDC) which provided grants for each child, but imposed an upper limit of $250/month. As such, recipients with large families received less aid per child than smaller families not affected by the maximum. Plaintiffs challenged the cap, arguing the state limit discriminated against them because of the size of their family in violation of the Equal Protection Clause of the 14th Amendment.

Issue.

Whether a federal aid program which results in disparity between small and large families is unconstitutional under the Equal Protection Clause of the 14th Amendment.

Held.

No. A federal aid program which results in disparity between small and large families is unconstitutional under the Equal Protection Clause of the 14th Amendment.

Dissent.

Justice Marshall

Concentration must be placed upon the character of the classification in question, the relative importance to individuals in the class discriminated against, and the asserted state interest. It cannot suffice to merely invoke the spectre of the past.

Discussion.

In the area of economics and social welfare, a state does not violate the Equal Protection Clause merely because the classifications made by its laws are imperfect. It is enough that 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.

The Constitution does not empower this Court to second-guess state officials charged with the difficult responsibility of allocating limited public welfare funds. Judgement reversed.