Wyman v. James

Supreme Court of the United States · 1970 · Property

400 U.S. 309 (1971)

Updated July 23, 2026

PropertyFourth AmendmentWelfare benefitsAdministrative searchesAFDChome visitwelfare caseworkeradministrative reasonableness

Facts

Barbara James received AFDC benefits for herself and her infant son, and a caseworker had visited her apartment without objection when she first applied. Two years later, a caseworker gave written notice of a planned home visit, and James said she would provide reasonable and relevant information but not in her home. The agency told her a home visit was required by law and that refusal would result in termination of assistance; after a hearing, her benefits were discontinued. James then brought a civil rights action claiming that conditioning benefits on allowing the home visit violated, among other things, the Fourth and Fourteenth Amendments.

Issue

May a state require an AFDC beneficiary to permit a home visit by a welfare caseworker as a condition of receiving continuing benefits, or does termination for refusal violate the Fourth Amendment because the visit is an unreasonable warrantless search?

Rule

A welfare home visit conducted under New York's AFDC scheme is not a search in the traditional Fourth Amendment sense when entry is not forced and refusal simply results in denial or cessation of aid. Even assuming the visit has some search characteristics, the Fourth Amendment forbids only unreasonable searches, and a limited, noncriminal, advance-noticed, nonforcible home visit serving valid welfare-administration purposes is reasonable.

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

In Cleveland, Ohio, Lena Ortiz receives state cash assistance for her two children through a federally funded family-support program. The agency mails her a letter scheduling a weekday home visit to verify continued eligibility and discuss available services; agency rules forbid forcible entry, false pretenses, and rummaging through rooms, and refusal results only in termination of benefits after a hearing.

If Lena refuses to allow the visit and her benefits are terminated, which is the strongest argument that the agency's action is constitutional?

Explanation. The majority held that a welfare home visit structured as advance-noticed, nonforcible, limited, and noncriminal is not a traditional Fourth Amendment search, and even if it has search-like features, it is reasonable. Key factors are the administrative purpose, lack of force, and consequence of refusal being cessation of aid rather than entry or prosecution.