Sullivan v. Stroop

Background

A federal agency (the Secretary of Health and Human Services) and several custodial parents receiving Aid to Families With Dependent Children (AFDC) disputed whether Social Security "child" benefits paid under Title II count as child support. Congress had amended AFDC rules in 1984 to require families to count children’s income but also created a $50 "disregard" for child support. The parents sued after agencies refused to ignore the first $50 of Title II payments when computing AFDC eligibility.

Reasoning

The Court asked whether the words "child support" in the AFDC rules include government-funded Title II child benefits. The majority concluded that within Title IV Congress used "child support" as a term of art referring to payments from absent parents, based on the statute’s structure and cross-references to the child-support program. Because the statutory language was clear in context, and because treating Title II benefits differently had a rational basis, the Court upheld the Secretary’s interpretation. The result: the Secretary prevailed and Title II child benefits are not covered by the $50 disregard.

Real world impact

States and federal agencies may count Social Security child benefits as income for AFDC eligibility, which can reduce or eliminate some families’ welfare payments. Families who receive Title II benefits may see smaller AFDC grants and less financial relief from the DEFRA change. The decision resolves a split among appeals courts and sets a uniform national rule.

Dissents or concurrances

Justices Blackmun, Brennan, Marshall, and Stevens disagreed. They argued ordinary meaning and the legislative history support treating Title II benefits as "child support" to avoid unfair reductions in aid.