Blum v. Bacon

Background

Several low-income mothers who rely entirely on AFDC (Aid to Families with Dependent Children) lost food, cash, or food stamps through theft and asked New York’s Department of Social Services for emergency help. New York law barred cash emergency assistance to anyone receiving or eligible for AFDC (the “no-cash” rule) and refused reimbursement for lost or stolen public assistance grants (the “loss-or-theft” rule). The women sued as a class; the lower courts reached differing conclusions after this Court’s earlier decision in Quern v. Mandley prompted a remand.

Reasoning

The central question was whether New York’s automatic exclusion of AFDC recipients from its emergency assistance program conflicted with federal law and federal rules. The Secretary of Health, Education, and Welfare had adopted a regulation requiring state plans to specify groups on reasonable bases and to avoid inequitable treatment. The Secretary also issued guidance saying AFDC recipients must be included in emergency assistance. The Court gave deference to the agency’s interpretation, found that New York’s no-cash and loss-or-theft provisions conflicted with the federal regulation, and held the state rules invalid under federal law because they treated AFDC recipients inequitably. The Court therefore resolved the case on statutory and regulatory grounds and did not decide the equal protection claim.

Real world impact

States that accept federal funds for emergency assistance cannot automatically exclude families on AFDC from cash aid or replacements for lost grants. Federal agency rules can disapprove state plans that exclude AFDC recipients, and states must provide emergency help consistent with the federal regulation. The Court’s ruling leaves open any separate constitutional challenges.