DANDRIDGE v. WILLIAMS

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Case Basics
Docket No. 
131
Appellant 
Edmund P. Dandridge, Chairman of the Maryland State Board of Public Welfare
Appellee 
Linda Williams et al.
Advocates
(Assistant Attorney General of Maryland, argued the cause for appellants)
(argued the cause for the appellees)
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Facts of the Case 

The Aid to Families with Dependent Children (AFDC) program, established by the Social Security Act of 1935 and jointly funded by the state and federal governments, provides financial assistance to children of families with little or no income. Under the program, each state computes a "standard of need" for each family. In Maryland, the standard of need increased with each additional member of the family, but became incrementally smaller, with an upper limit of $250 per month. Linda Williams, a single mother, and Junius and Jeanette Gary, husband and wife, were Baltimore residents and parents of eight children each. They objected to Maryland's means of calculating standard of need on the ground that it discriminated against larger families, in violation of the Equal Protection Clause. They also argued that the calculation conflicted with the stated purpose of the program as laid out by the Social Security Act. They filed suit against Edmund P. Dandridge, Chairman of the Maryland State Board of Public Welfare, and several other state officials. A U.S. District Court originally ruled the Maryland regulation violated both the Social Security Act and the Equal Protection Clause. On reconsideration, the court altered its ruling and based its judgment entirely on constitutional grounds but nonetheless struck down the provision.

Question 

Did the Maryland mechanism for computing standard of need violate either the Equal Protection Clause of the Fourteenth Amendment or the Social Security Act of 1935?

Conclusion 
Decision: 5 votes for Dandridge, 3 vote(s) against
Legal provision: Aid to Families with Dependent Children (AFDC--provisions of the Social Security Act)

No. In a 5-3 opinion authored by Justice Potter Stewart, the Court concluded that the Maryland provision violated neither the Social Security Act nor the Equal Protection Clause. Relying on the precedent set in King v. Smith (1968), which described the program as "a scheme of cooperative federalism" and gave the state "undisputed power" to calculate standard of need, the Court concluded that "nothing in the federal statute…forbids a State to balance the stresses that uniform insufficiency of payments would impose on all families against the greater ability of large families…to accommodate their needs to diminished per capita payments." Similarly, the Court rejected the families' equal protection claim, noting, "[T]he 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." Thus, because Maryland's provision was "rationally based and free from invidious discrimination," it was constitutionally valid. Justice Stewart took care to note that while "claims of morality and intelligence are raised by opponents and proponents of almost every measure," the Court could rule a provision invalid based only on its constitutionality, not on its wisdom.

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DANDRIDGE v. WILLIAMS. The Oyez Project at IIT Chicago-Kent College of Law. 11 September 2014. <http://www.oyez.org/cases/1960-1969/1969/1969_131>.
DANDRIDGE v. WILLIAMS, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1969/1969_131 (last visited September 11, 2014).
"DANDRIDGE v. WILLIAMS," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 11, 2014, http://www.oyez.org/cases/1960-1969/1969/1969_131.