Lewis v. Martin
Headline: Court upholds federal rule blocking states from counting a stepfather’s or 'man‑in‑the‑house' income against welfare families unless he actually contributes, protecting recipients from automatic benefit cuts.
Holding: The Court reversed the district court and ruled that federal HEW regulations validly forbid California from treating a stepfather's or a man‑in‑the‑house’s income as available for AFDC benefits absent proof of actual contributions.
- Stops automatic cuts to AFDC benefits based solely on a man living in the home.
- Requires states to prove a stepfather or MARS actually contributes before reducing payments.
- Leaves questions about nonadopting stepfathers for lower courts to decide on remand.
Summary
Background
Appellants are mothers and children who receive welfare under California law. At the time, California automatically treated the income of a stepfather or a man assuming the role of spouse (called a MARS) as available to the family and reduced benefits on that basis. HEW had adopted a regulation saying a state may not count a man’s income unless there is proof he actually contributes. The families sued to invalidate California’s rule, and a three‑judge District Court held the HEW regulation invalid.
Reasoning
The Court considered whether HEW permissibly required proof of actual contribution before a state could treat a man’s income as available for Aid to Families With Dependent Children (AFDC). Relying on earlier decisions, the majority concluded HEW’s regulation reasonably interpreted the federal statute and was consistent with Congress’s focus on persons who have a legal duty to support. The Court said HEW could refuse to presume support from a MARS or a nonadopting stepfather unless the state shows real contributions or a legal obligation. The Court reversed the District Court and sent the case back so the lower court can decide remaining questions about nonadopting stepfathers.
Real world impact
The ruling prevents states from automatically reducing AFDC payments just because a stepfather or MARS lives in the home. Families will keep benefits unless the state proves the man contributes or is legally obligated to support the children. The decision gives deference to the federal agency that runs the program and leaves factual or legal disputes about some stepfather situations to be resolved on remand.
Dissents or concurrances
Justice Black, joined by the Chief Justice, dissented, arguing the suit was premature because HEW procedures had not been exhausted and the federal agency should have primary jurisdiction to resolve the dispute.
Opinions in this case:
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