Saturday, December 7, 2013

Dandridge v. Williams case brief

Dandridge v. Williams case brief summary
397 U.S. 471 (1970)


CASE SYNOPSIS
In an action brought by respondent welfare recipients, petitioner State of Maryland appealed a judgment from the United States District Court for the District of Maryland holding that its Aid to Families With Dependent Children (AFDC) statute, Md. Code Ann., Art. 88A, § 44A et seq. (1969 Repl. Vol.), which contained a "maximum grant" provision, violated the Equal Protection Clause of U.S. Constitutional Amendment XIV.

CASE FACTS
The welfare recipients brought an action challenging the validity of Maryland's Aid to Families With Dependent Children statute, Md. Code Ann., Art. 88A, § 44A et seq. (1969 Repl. Vol.), on the grounds that its "maximum grant" provision did not comply with the Social Security Act of 1935, 42 U.S.C.S. § 602(a)(10), and violated the Equal Protection Clause of U.S. Constitutional Amendment XIV. The lower court granted the recipients judgment on the constitutional ground.

DISCUSSION
  • The court reversed, holding first that the maximum grant provision did not violate § 602(a)(10), which required that aid be furnished with reasonable promptness "to all eligible individuals." 
  • The Social Security Act did not require that the aid furnished must equal the total of each individual's standard of need in every family group, but only that some aid was provided to all eligible families and all eligible children. 
  • 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.

CONCLUSION
The court reversed the district court's judgment in favor of the welfare recipients in their suit to invalidate Maryland's Aid to Families With Dependent Children statute.

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