Batterton v. Francis

Background

This dispute began when Maryland officials denied certain families AFDC-UF welfare because the fathers were out of work for reasons that disqualified them from state unemployment benefits. Families whose fathers were fired for misconduct, on strike, or who quit challenged the Maryland rule. The federal agency (HEW) had revised a national regulation to say states may, at their option, exclude fathers whose unemployment stems from labor disputes or disqualifying conduct.

Reasoning

The Court addressed whether the Secretary of HEW exceeded the authority Congress gave in the Social Security Act when adopting that regulation. The majority explained that Congress expressly gave the Secretary power to set standards for who counts as “unemployed” for AFDC-UF purposes. Because Congress delegated that authority, the Court treated the agency’s regulation as reasonable and within the delegated power. The Court therefore reversed the lower courts that had struck the regulation down and blocked the Maryland rule.

Real world impact

Practically, the decision lets each participating state choose whether to deny AFDC-UF to families whose fathers are disqualified under state unemployment rules or are on strike. That preserves state options within the federal program and can produce variation in who receives federal-family assistance, though states may also opt out of the program entirely.

Dissents or concurrances

Justice White (joined by three others) dissented, arguing the legislative history shows Congress wanted a uniform federal definition of unemployment and that the regulation improperly returns important coverage choices to the states.