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Woods v. Miller

United States District Court for the Western District of Pennsylvania · 1970 · Constitutional Law

Constitutional LawAFDCSocial Security ActPublic WelfareAFDCSocial Security Actstate planeligibility

Facts

Pennsylvania regulations required an indigent AFDC recipient to sue any legally responsible relative whom the Department deemed financially able to contribute support, and refusal to sue resulted in discontinuance of assistance for members of the assistance unit for whom that relative was legally responsible. Mary Woods and her minor niece Patricia Jones had been receiving AFDC assistance as a family unit. After the Department concluded that Woods's adult daughter could contribute support, Woods was told to sue her daughter; when she refused, Woods was declared ineligible and the household grant was reduced from $202 to $136, leaving only Patricia's one-person grant.

Issue

May a state participating in the AFDC program reduce or deny assistance to an AFDC family unit by requiring a recipient, as a condition of eligibility, to initiate court action against a legally responsible relative for support?

Rule

Under the Social Security Act's AFDC provisions, aid must be furnished promptly to all eligible individuals, and a state may not impose an additional condition of eligibility unrelated to the statutory criteria of need and dependence. A regulation that reduces assistance to an otherwise eligible AFDC family unit because a recipient refuses to initiate support litigation against a relative is invalid.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, Lena Ortiz lives in Cleveland with her 11-year-old grandson, Mateo, and both receive AFDC as one household. State welfare rules require Lena to file a support action against her financially able adult sister in Toledo; when Lena refuses, the agency cuts the household grant by removing Lena's portion, leaving only Mateo's individual amount.

Under the governing rule, is the Ohio rule valid as applied?

Explanation. The majority rule is that a participating state may not deny or reduce AFDC to an otherwise eligible assistance unit by imposing an extra eligibility requirement beyond need and dependence. A rule requiring the caretaker to sue a legally responsible relative, with loss of benefits upon refusal, is invalid because it reduces assistance to the family unit, including otherwise eligible dependent children.