Philbrook v. Glodgett

Background

Families in Vermont sued after state welfare officials cut off or denied aid because the children’s fathers were eligible for unemployment compensation. Vermont’s welfare rule defined an "unemployed father" to exclude anyone receiving or eligible for unemployment pay. The families sued the Vermont welfare commissioner and the federal health secretary, and a three-judge District Court held that the federal law’s phrase "receives unemployment compensation" means actual receipt of the check, not mere eligibility, and enjoined the Vermont rule.

Reasoning

The central question was whether the federal statute disqualifies families only when a father actually gets unemployment payments or also when he is merely eligible. The Court examined the statute’s text, the 1968 congressional amendments, and how the AFDC program treats other income, concluding that Congress intended "receives" to mean actual payment for the weeks in question. Because Congress made the federal coverage mandatory once a State elected the program, Vermont’s broader exclusion (denying aid when fathers are only eligible) conflicted with the statute and could not be applied.

Real world impact

The ruling overturns Vermont’s regulation in these cases and requires that AFDC-style federal benefits continue for weeks when a father has not actually received unemployment compensation. States participating in the federal program cannot refuse aid simply because a father is eligible for unemployment pay; benefits terminate only for weeks when the father actually receives such payments.