Lascaris v. Shirley
Headline: New York’s welfare rule requiring recipients to help obtain child support is upheld after Congress amended federal law, allowing states to condition benefits on cooperation with paternity and support actions.
Holding:
- Allows states to require welfare recipients to cooperate in paternity and support actions.
- Makes cooperation a condition for benefits under the amended federal law.
- Federal amendment takes effect July 1, 1975, changing eligibility rules immediately.
Summary
Background
New York amended its Social Services Law to require welfare recipients to cooperate in paternity or child-support actions as a condition of eligibility for Aid to Families with Dependent Children (AFDC). A three-judge District Court held that the state requirement conflicted with the federal Social Security Act and invalidated the state provision. The State and county welfare officials appealed to the Supreme Court.
Reasoning
Before the Court could prepare an extended opinion, Congress on January 4, 1975, enacted Pub. L. 93-647 and amended §402(a) of the Social Security Act to require recipient cooperation in establishing paternity and obtaining support. The Supreme Court noted that the federal amendment resolved the previously identified conflict between state and federal law, cited earlier decisions, and affirmed the three-judge court’s judgment without issuing a lengthy opinion.
Real world impact
Because federal law was amended to mirror New York’s rule, states may condition AFDC eligibility on cooperation in paternity and support actions once the amendment takes effect. The statute specifies an effective date of July 1, 1975. The opinion also records the President’s statement that he planned to propose further changes in the next Congress, indicating possible future legislative revisions.
Dissents or concurrances
The Chief Justice, Justice Powell, and Justice Rehnquist dissented from the Court’s per curiam disposition. The opinion does not summarize their reasons, but it notes their disagreement with the disposition.
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