Roe v. Norton
Headline: Court vacates lower-court ruling and remands a case about requiring AFDC mothers to name putative fathers, ordering reconsideration after Congress added federal cooperation requirements for paternity efforts.
Holding: The Court vacated the District Court’s judgment and remanded for reconsideration under the new federal AFDC cooperation law and for possible abstention if state criminal proceedings exist.
- Requires mothers on AFDC to cooperate with paternity-location efforts.
- Lower court must re-evaluate constitutionality under the new federal law.
- Federal courts should consider avoiding interference with pending state criminal cases.
Summary
Background
A group of mothers receiving Aid to Families With Dependent Children (AFDC) and their children challenged a Connecticut law that forces a mother of an out-of-wedlock child to give the name of the child’s suspected father under oath. The state law threatened contempt, up to one year in jail and a $200 fine, for a mother who refused. A three-judge federal District Court had upheld the statute against claims about due process, equal protection, and privacy.
Reasoning
After the Supreme Court noted probable jurisdiction, Congress passed a law amending the Social Security Act to require parents who receive AFDC to cooperate with state efforts to locate and get support from absent parents. The added federal rule does not include the same criminal or jail penalties Connecticut’s law provides. The Court therefore vacated the District Court’s judgment and sent the case back so the lower court can reconsider the state statute in light of the new federal law. The Court also told the lower court to consider federal abstention principles if a related state criminal proceeding is pending.
Real world impact
The remand means the lower court must rethink whether the Connecticut enforcement scheme is appropriate now that federal AFDC rules require cooperation. Mothers on AFDC, state welfare agencies, and courts may face changed enforcement or relief depending on the lower court’s reconsideration. This decision is procedural, not a final judgment on the law’s constitutionality, so outcomes could change on remand.
Dissents or concurrances
Justice Douglas joined most of the Court’s action but did not agree with applying the Court’s instructions about abstaining from pending state criminal cases.
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