Blessing v. Freestone

Background

Five Arizona mothers sued the director of the State’s child support agency, saying the agency failed to provide the services their children are entitled to under Title IV-D of the Social Security Act. They sought classwide relief and asked a court to require the State to achieve “substantial compliance” with federal child support rules. The District Court ruled for the State, the Ninth Circuit reversed, and the Supreme Court took the case to resolve the disagreement among appeals courts.

Reasoning

The Court addressed whether Title IV-D creates enforceable individual rights that allow people to sue state officials under 42 U.S.C. § 1983 (the federal law that lets people sue when a state deprives them of federal rights). The Justices explained the three-part test courts use: whether Congress intended to benefit the plaintiff, whether the claimed right is concrete enough for courts to enforce, and whether the law imposes a clear, mandatory obligation on the State. The Court held that the program-wide “substantial compliance” standard is a tool for federal oversight and penalties, not an individual entitlement. The Court vacated the Ninth Circuit’s broad ruling and sent the case back so the lower court can identify any specific statutory provisions that might create individual rights.

Real world impact

The decision makes it harder for parents to bring broad lawsuits forcing a State to overhaul its entire child support system based on the general “substantial compliance” yardstick. Individual parents may still be able to sue over narrowly defined rights (for example, specific payment pass-through rules), but those claims must be stated clearly. The ruling is not a final determination on any particular claim; the case was remanded for further proceedings.

Dissents or concurrances

Justice Scalia, joined by Justice Kennedy, concurred. He agreed with the result under the Court’s test but noted a separate, unsettled question about whether beneficiaries of federal-state funding arrangements can generally sue as third-party beneficiaries.