Maine v. Thiboutot
Headline: Ruling allows people to sue state agencies under the civil-rights law for breaches of federal statutes like the Social Security Act and permits attorney-fee awards, affecting welfare claimants and state officials nationwide.
Holding: The Court held that the civil-rights law, Section 1983, covers violations of federal statutes like the Social Security Act, and that Section 1988 permits attorney-fee awards in those suits, including in state courts.
- Lets welfare recipients sue state agencies for statutory benefits violations.
- Authorizes recovery of attorney’s fees in such cases, including state-court suits.
- Raises potential liability for state and local officials administering federal programs.
Summary
Background
Lionel and Joline Thiboutot, a married couple with eight children, sued the State of Maine and its Commissioner of Human Services after the State changed how it calculated AFDC welfare payments. The State stopped counting money Lionel spent supporting five children not born to his current marriage, even though he had a legal obligation to support them. After exhausting administrative appeals, the family sued in Maine Superior Court and added a claim under the federal civil-rights law, saying the State had violated the Social Security Act.
Reasoning
The Supreme Court addressed two questions: whether the civil-rights statute (Section 1983) covers claims based only on federal statutes, and whether the attorney-fee statute (Section 1988) allows fee awards in those cases. The majority relied on the plain text—“rights…secured by the Constitution and laws”—and on prior decisions that had treated statutory claims under Section 1983. The Court held that Section 1983 does reach violations of federal statutes like the Social Security Act and that Section 1988 authorizes reasonable attorney’s fees in such suits.
Real world impact
The Court affirmed the Maine courts’ view that the family could pursue their statutory claim under Section 1983 and that fees can be awarded; the Maine Supreme Court must now let the Superior Court decide the fee request. The decision means people challenging state administration of federal programs can bring statutory claims under Section 1983 and may recover fees, including when cases are heard in state courts.
Dissents or concurrances
A dissent argued this reading greatly expands state liability, questioned the historical basis for the majority’s view, and warned of wide consequences for many federal-state programs.
Opinions in this case:
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