Dandridge V. Williams
Factual Background: The Social Security Act of 1935 implemented the Aid to Families with Dependent Children (AFDC) program, which was jointly funded by the state and federal governments. The objective of the program is to grant financial assistance to children who come from indigent families with insufficient or no income. It is the state that will determine the computation of the “standard of need” required for every family. In the state of Maryland, the standard of need had given an increase for each additional member of the family. However, the increment was reduced since there was an upper limitation that was provided at $250 per month.
The computation that was used by the state of Maryland in determining the standard need of the family was questioned by Linda Williams and spouses Junius and Jeanette Gary on the ground that it violated the Equal Protection Clause of the Constitution. Both Williams and spouses Gary, residents of Baltimore had 8 children each. They alleged that the computation contravenes the purpose of the program pursuant to the Social Security Act. They filed a case against Dandridge, who was Chairman of the Maryland State Board of Public Welfare. The District Court ruled in favor of Williams and Gary.
Constitutional question: Whether or not the Maryland regulation violate the Equal Protection Clause and the Social Security Act.Ruling: The Supreme Court ruled on the validity of the Maryland regulation. It was held that under the scheme of cooperative federalism, the state was granted the definite power to compute the standard of need of each family.
Reasoning: The federal statute did not prohibit the state of Maryland to even out the stresses that standardized the deficiency of payments that it will impose on every family against the greater capacity of big families for the purpose of accommodating the needs of the family to reduced per capita payments. There was no violation of the Equal Protection Clause because the State has to liberty to choose on how to appropriate its funds and cannot be faulted for low appropriations. Future Constitutional implications: The State of Maryland has the power to decide on how to distribute the funds as it deems suitable, on the basis of parameters established by law. The act of the state does not amount to discrimination since it was within the bounds of law.
