WYMAN v. JAMES

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Case Basics
Docket No. 
69
Appellee 
George K. Wyman, Commissioner of the State of New York Department of Social Services
Appellant 
Barbara James et al.
Advocates
(Assistant Attorney General of New York, argued the cause for appellant Wyman)
(argued the cause for the appellee)
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Facts of the Case 

Barbara James and her son Maurice lived in the Bronx, New York City. Shortly after Maurice's birth, Barbara James applied for assistance under New York State's Aid to Families with Dependent Children program (AFDC). James began receiving assistance after a caseworker visited her apartment. Two years later, James was scheduled to be visited again by a caseworker. This visit was required under New York State law and would affect her benefits under AFDC. She refused to allow this visit. In a procedural hearing, she continued her refusal, and her AFDC assistance was terminated by New York State as a result. James then filed suit under Section 1983 of the Civil Rights Act of 1871 in United States District Court for the Southern District of New York alleging that the caseworker visit was a search and would violate her Fourth and Fourteenth Amendment rights. The District Court ruled in her favor. New York appealed.

Question 

Did New York violate James' Fourth and Fourteenth Amendment rights in terminating her AFDC benefits when she refused the caseworker visit?

Conclusion 
Decision: 6 votes for Wyman, 3 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

No. In a 6-3 opinion, the Court held that a caseworker visit was not a "search" under the Fourth Amendment. Writing for the majority, Justice Harry A. Blackmun reasoned that "the visitation in itself is not forced or compelled," and as a result, "there is no entry of the home and there is no search." Even if the caseworker visit "does possess some of the characteristics of a search in the traditional sense," the visit still would not violate the Fourth Amendment, under the unreasonableness standard set forth in Terry v. Ohio. The Court concluded that the caseworker visit was not unreasonable, as the visit allowed the state to focus on the child and to ensure that its welfare funds were being used properly. Moreover, the visit was not confrontational and James' refusal did not lead to criminal prosecution. Justice Byron R. White concurred in the judgment.

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WYMAN v. JAMES. The Oyez Project at IIT Chicago-Kent College of Law. 20 June 2014. <http://www.oyez.org/cases/1970-1979/1970/1970_69>.
WYMAN v. JAMES, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1970-1979/1970/1970_69 (last visited June 20, 2014).
"WYMAN v. JAMES," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 20, 2014, http://www.oyez.org/cases/1970-1979/1970/1970_69.