Engelman v. Amos

Background

Amos, who challenged New Jersey officials, brought a suit about how the State calculated Aid to Families With Dependent Children (AFDC) payments. New Jersey regulation §615 treated a family's "total available adjusted income" without subtracting the "income disregards" required by the federal law, and it did not ensure stepfather earnings were counted only when actually available to the child. The District Court also considered a related rule (§615.5) that allowed direct payments to vendors. A three-judge federal court enjoined enforcement and ordered New Jersey to revise the rules. Amos was allowed to proceed without paying fees.

Reasoning

The Court reviewed whether the state regulation conflicted with federal law and federal rules about counting family income. The lower court had concluded the state law violated federal requirements and blocked the rule. This Court agreed generally, affirming the injunction against the §615 formula that ignored federal income disregards and the stepfather-earnings standard. However, the Court clarified that nothing in the federal statute forbids a State from making vendor payments entirely with state funds without federal reimbursement, so the District Court’s ruling is limited.

Real world impact

The decision means states administering AFDC must follow federal rules when computing family income and when treating stepfather earnings, or face an injunction. At the same time, states retain the option to make direct payments to vendors if those payments come solely from state money and are not submitted for federal reimbursement. Recipients, state welfare agencies, and vendors will see how benefit calculations and payment methods are applied under these clarified limits.