Shea v. Vialpando

Background

A Colorado woman who received Aid to Families with Dependent Children (AFDC) lived eight miles from work and used her car because no public transportation was available. Colorado changed its rule to a $30 per month standardized work-expense allowance for most job-related costs. That change reduced her allowable deductions, raised her counted income, and made her ineligible for AFDC. She sued, and lower courts enjoined the Colorado rule before the case reached this Court.

Reasoning

The Court examined the AFDC statute’s command that the State “take into consideration . . . any expenses reasonably attributable to the earning of . . . income.” It held that the word “any” and the law’s history show Congress intended reasonable work expenses to be considered on an individual basis. A flat dollar cap that prevents someone from showing higher reasonable expenses conflicts with that command. The Court said a standard allowance is permissible only if it still permits individualized consideration when actual expenses exceed the standard.

Real world impact

The decision invalidates Colorado’s $30 maximum as applied and affirms the lower courts’ judgments. States that use fixed maximums without a way for recipients to prove higher reasonable costs must change those practices. The ruling affects recipients with high job-related costs, and it requires state welfare agencies to allow individual proof of reasonable employment expenses when computing benefits.