Miller v. Youakim

Background

Four foster children and their relatives sued Illinois after the State refused higher Foster Care payments when the children were placed with relatives. The children had been removed by court order for neglect and initially received full foster-care payments in unrelated homes. Illinois paid only smaller basic welfare benefits for relatives' placements because state rules defined "foster family home" to exclude relatives. Lower federal courts ruled for the children, and a federal agency issued an instruction saying relatives' licensed or approved homes qualify for foster-care payments.

Reasoning

The Court asked whether the federal Foster Care law's phrase "foster family home" includes licensed or approved homes operated by relatives. The Justices looked at the statute's plain language, its history, and the federal agency's interpretation. They concluded the law's broad definition covers any home a State licenses or approves for foster care. Congress intended the program to meet the needs of neglected children, not to treat them differently because of who cares for them. The Court therefore held Illinois may not deny federal foster-care benefits and services when a child is placed with a relative who meets the State's licensing or approval standards.

Real world impact

The decision requires Illinois and other States to provide the higher foster-care payments and services to eligible children placed with licensed or approved relatives. It affects foster children, relatives who care for them, and state agencies that license and pay for foster care. The ruling enforces federal standards over conflicting state rules.