Califano v. Westcott

1979-06-25

Headline: Federal rule limiting AFDC unemployment aid to fathers is struck down, and the Court orders equal benefits when a mother loses her job, expanding support for families where mothers were the primary earners.

Holding: The Court held that the AFDC provision limiting unemployment-based benefits to families with an unemployed father violates the Fifth Amendment and affirmed the order requiring equal benefits when a mother loses her job.

Real World Impact:

Requires AFDC unemployment aid when either parent is unemployed, not just fathers.
Triggers federal matching funds to cover benefits for families with unemployed mothers.
Leaves detailed eligibility changes to Congress and state agencies, not the courts.

Topics: welfare benefits, sex discrimination, family financial support, unemployment policy

Summary

Background

Two Massachusetts couples — each with an infant and each saying the mother had been the family breadwinner — applied for AFDC-related benefits after the mother lost her job and were denied because the federal statute provided such unemployment-based aid only when the father was unemployed. They sued, the District Court certified a class, and held the gender-based provision (§ 407) unconstitutional, ordering that benefits be paid to families made needy by a mother’s unemployment on the same terms as when the father is unemployed. The Secretary of HEW appealed the constitutional ruling; the State welfare commissioner accepted the merits but sought a narrower remedy.

Reasoning

The Court asked whether conditioning AFDC-UF benefits on the parent’s sex was justified. It concluded the gender limitation discriminated against families where the mother was the wage earner, rested on outdated stereotypes, and was not substantially related to stated goals like preventing paternal desertion. The Court reviewed the legislative history showing the 1968 change added a father-only requirement largely to reduce costs and assumed fathers were breadwinners. Given the constitutional defect, the Court affirmed the District Court’s extension remedy rather than nullifying the program, noting hardship to current beneficiaries and a severability clause.

Real world impact

The ruling requires that families qualify for AFDC-UF benefits when either parent is unemployed under existing standards, triggers federal matching funds for those payments, and leaves finer eligibility choices to Congress or state agencies rather than the courts.

Dissents or concurrances

A separate opinion agreed the statute was unconstitutional but argued the court should have stopped payments and left Congress to redesign eligibility rather than extend benefits by judicial order.