Youakim v. Miller

Background

A foster family in Illinois (the Youakims) cared for two of Linda Youakim’s related children and received lower state payments than unrelated foster homes. Illinois paid $105 per month under the federal foster-care program to unrelated foster parents, but related foster parents received smaller monthly AFDC payments of $63 and could only get extra need-based supplements. The Youakims sued state officials, saying the payment rules treated related families worse and conflicted with federal policy encouraging care in relatives’ homes. A three-judge District Court granted summary judgment for the state, finding no unequal treatment.

Reasoning

The Supreme Court noted that the lower court had not separately decided whether Illinois’s payment rules conflicted with the federal Social Security Act. Since the Department of Health, Education, and Welfare later issued guidance saying the foster-care rate should apply even when the foster parents are relatives, and the Solicitor General told the Court the state law looked inconsistent with federal law, the Justices concluded the Youakims should be allowed to press that statutory conflict before the District Court. The Court vacated the judgment and sent the case back so the lower court can first decide whether Illinois’s program violates federal law; if it does, the Court said the constitutional equal-treatment question need not be reached.

Real world impact

The remand gives the District Court a chance to apply the federal agency’s interpretation and the Solicitor General’s position. If the court finds a conflict, Illinois might have to change who gets the higher foster-care payments, which could affect whether relatives can take children into their homes without financial barriers. This ruling is not a final decision on the merits and could change on further review.