Townsend v. Swank

Background

Two college students and their mothers sued Illinois after the State cut off AFDC payments when the students enrolled in junior college. Illinois law and a state regulation limited AFDC eligibility for 18–20-year-olds to those in high school or vocational training and expressly excluded college students. The District Court upheld the Illinois rules; the Supreme Court granted review after appellants showed loss of monthly family income of $23.52 and $47.94 in two example households.

Reasoning

The Court asked whether a State that participates in the federal AFDC program may refuse benefits to needy 18–20-year-olds who are attending college. It examined the federal statute, §406(a)(2)(B), and legislative history and found that federal law makes students attending school, college, or vocational training eligible. The Court relied on the statutory requirement that aid be furnished to all eligible individuals and on prior decisions limiting state rules that conflict with federal standards. Because Illinois’ college exclusion directly conflicted with the federal definition of eligible students, the Court held the state rule invalid under the Supremacy Clause and reversed the lower court without deciding the separate equal protection claim.

Real world impact

States that participate in AFDC must conform their eligibility rules to the federal student standard if they want federal participation. In practical terms, Illinois’ exclusion of college students cannot be used to deny AFDC to needy students under 21, and affected families may have their benefits restored. The Court’s ruling resolved the federal-state conflict but left the equal protection question undecided.

Dissents or concurrances

Chief Justice Burger concurred in the result, noting Title IV governs federal funding and emphasizing the inquiry whether a State has adhered to federal requirements to receive federal funds.