Dandridge v. Williams
Headline: Court upholds Maryland's cap on family welfare payments, allowing states to limit monthly AFDC grants and affecting large families' per‑child aid while preserving state budgeting discretion.
Holding: The Court ruled that Maryland's 'maximum grant' cap on monthly AFDC family payments does not violate the Social Security Act or the Fourteenth Amendment, allowing states to impose such limits to allocate limited welfare funds.
- Allows states to cap monthly welfare checks for families
- May reduce per-child payments for large families
- Encourages states to allocate limited AFDC funds across more households
Summary
Background
This case was brought by several families on AFDC who say Maryland's rule cuts off needed payments to some children. Maryland computes a "standard of need" for each family but caps any family's monthly grant at $250 in some counties (including Baltimore City) and $240 elsewhere. The plaintiffs' computed needs exceed that cap. A three‑judge District Court found the cap unconstitutional; Maryland appealed to the Supreme Court.
Reasoning
The Court first asked whether the cap violated the Social Security Act and concluded it did not. It said the Act gives states wide latitude to set need standards and benefit levels, noted the federal agency had approved Maryland's plan, and observed many states use similar family maximums. The Court also cited a 1967 amendment that recognized state maximums. On equal protection, the Court applied a deferential rational‑basis standard and accepted state justifications — encouraging work by letting recipients keep earned income, balancing welfare and low‑wage families, promoting family planning, and stretching limited funds — so it reversed the District Court.
Real world impact
The ruling allows Maryland and other states that use family maximums to continue capping monthly AFDC grants. Large families whose computed need exceeds the cap will receive lower per‑child payments. The decision leaves allocation choices about how to stretch limited welfare budgets largely to state officials and keeps federal oversight focused on statutory and constitutional limits rather than on specific benefit formulas.
Dissents or concurrances
Two Justices dissented, saying the cap conflicts with the Social Security Act and denies aid to eligible children, and that it encourages breaking up large families to get separate grants. Two other Justices wrote separately: one joined the Court's result; another agreed but warned about the standard of review.
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