436 U.S. 725 (1978), 76-1159, Quern v. Mandley
|Docket Nº:||No. 76-1159|
|Citation:||436 U.S. 725, 98 S.Ct. 2068, 56 L.Ed.2d 658|
|Party Name:||Quern v. Mandley|
|Case Date:||June 06, 1978|
|Court:||United States Supreme Court|
Argued November 30, 1977
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SEVENTH CIRCUIT
This litigation originated as a challenge to the validity of Illinois' Emergency Assistance to Needy Families with Children (EA) program under Title IV-A of the Social Security Act (SSA). The Court of Appeals, reversing the District Court, first held that the program was invalid because it limited eligibility for such assistance more narrowly than § 406(e)(1) of the SSA, which makes [98 S.Ct. 2070] federal matching funds available under a state EA program for emergency aid to intact families with children if threatened with destitution, regardless of the cause of the need. In a later appeal involving the validity of a proposed alternative to the EA program, the Court of Appeals held that § 403(a)(5) of the SSA, which authorizes federal funding of a state EA program, is the exclusive source of federal funds for a state program of emergency assistance, and that therefore a new "special needs" program that Illinois proposed to operate under its Title IV-A Aid to Families with Dependent Children (AFDC) program, funded under § 403(a)(1) of the SSA, in place of its withdrawn EA program, must, as a de facto EA program, extend aid to all persons eligible under § 406(e)(1).
1. There is nothing in the policies or history of the EA statute to indicate that Illinois' proposed "special needs" program should not be judged solely under the requirements for an AFDC program funded under § 403(a)(1) without regard to the EA requirements of §§ 406(e) and 403(a)(5). Pp. 735-736.
2. The proposed "special needs" program is permissible as part of an AFDC program alone. A plan to meet certain emergency needs of AFDC recipients -- specifically actual or threatened loss of shelter due to damage or eviction -- is not necessarily improper as an AFDC "special needs" program simply because it addresses a nonrecurring need that could alternatively be provided for under an EA program. Pp. 737-739.
3. Neither § 402(a)(10) of the SSA, which makes AFDC, not EA, eligibility criteria mandatory, nor § 406(e), which defines the permissible
scope of an EA program for purpose of federal funding, imposes mandatory eligibility standards on States that elect to participate in the EA program, and therefore Illinois is not precluded from receiving matching federal funds for either an EA or a "special needs" program simply because it limits eligibility for aid under that program more narrowly than § 406(e). Pp. 739-747.
545 F.2d 1062, reversed and remanded.
STEWART, J., delivered the opinion of the Court, in which all other Members joined except BLACKMUN, J., who took no part in the consideration or decision of the cases.
STEWART, J., lead opinion
MR. JUSTICE STEWART delivered the opinion of the Court.
These cases require examination of the interplay between state option and federal mandate within the system of cooperative federalism created by the public assistance programs of Title IV-A of the Social Security Act, 42 U.S.C. § 601 et seq. The ultimate question to be decided is whether a
State may ever receive federal matching funds for a program of emergency assistance to needy families, either under the general program of Aid to Families with Dependent Children (AFDC)1 or under the specific provisions for Emergency Assistance to Needy Families with Children (EA),2 [98 S.Ct. 2071] if it limits
eligibility for such aid more narrowly than the federal EA statute.
Title IV-A of the Social Security Act establishes several different public aid programs under the general rubric of "Grants to States for Aid and Services to Needy Families with Children." In order to receive federal funds under any of the Title IV-A programs a State must adopt a "state plan for aid and services to needy families with children" that is approved by the United States Department of Health, Education, and Welfare (HEW) as meeting the requirements set forth in § 402 of the Act.
AFDC is the core of the Title IV-A system. As the Court observed in one of its earliest forays into Title IV, AFDC is a categorical aid program, and
the category singled out for welfare assistance . . . is the "dependent child," who is defined in § 40B of the Act . . . as an age-qualified "needy child . . . who has been deprived of parental support or care by reason of the death, continued absence from the home, or physical or mental incapacity of a parent, and who is living with" any one of several listed relatives.
King v. Smith, 392 U.S. 309, 313. A State's expenditures for AFDC, under an approved § 402 state plan, are reimbursed by the Federal Government according to the formula set forth in § 403(a)(1).
The federal EA program was added to Title IV as part of the omnibus Social Security Amendments of 1967. Pub.L. 90-248, § 206, 81 Stat. 893. It was described in the Senate Finance Committee report as
a new program optional with the States [to] authorize dollar-for-dollar Federal matching to provide temporary assistance to meet the great variety of situations faced by needy children in families with emergencies.
S.Rep. No. 744, 90th Cong., 1st Sess., 4 (1967).
To participate in the program, a State must include a provision for EA in its § 402 state plan, and funding at a flat rate of 50% of program expenses is authorized by § 403(a)(5).
Unlike AFDC, eligibility for EA is not limited to "dependent children." Instead, the term "emergency assistance to needy families with children" is broadly defined in § 406(e) to include money payments and other kinds of aid provided on a temporary basis "to avoid destitution . . . or to provide living arrangements" for a "needy child under the age of 21 who is . . . without available resources." 42 U.S.C. § 606(e)(1). Thus, under the EA statute, federal matching funds are available for emergency aid to intact families with children if threatened with destitution, regardless of the cause of their need.
The State of Illinois, however, elected to adopt an EA program of much narrower scope. It provided only for (1) aid to AFDC families who were without shelter as a result [98 S.Ct. 2072] of either damage to their homes or court-ordered eviction for reasons other than nonpayment of rent; and (2) aid to applicants determined to be presumptively eligible for AFDC who were in immediate need of clothing or household furnishings.
In 1973, the respondents instituted a class action against state and federal officials on behalf of all "AFDC recipients, applicants for AFDC, and other families with needy children" in Illinois seeking a declaratory judgment that the Illinois EA program violated federal law by defining eligibility more narrowly than 406(e)(1), and an injunction restraining the defendants from administering the allegedly unlawful program.3 The United States District Court for the Northern
District of Illinois held, in an unreported opinion, that the State's program was not inconsistent with federal law. The Court of Appeals for the Seventh Circuit reversed this judgment, ruling that
Illinois may no longer conduct an emergency assistance program under [§ 406(e)] in which some of the families with needy children described in [§ 406(e)] are given aid and some are not.
Mandley v. Trainor, 523 F.2d 415, 423 (Mandley I).
After the Court of Appeals' mandate was returned to the District Court, the plaintiffs submitted a proposed final order requiring the State to conform its EA program to the provisions of § 406(e) and further requiring the federal defendants to promulgate regulations consistent with the Court of Appeals' interpretation of the statute. The state and federal defendants not only opposed the substantive terms of the proposed order, but also filed motions to dismiss the complaint altogether on the ground that the case had been rendered moot by the State's decision to withdraw entirely from the EA program. In support of its motion, the State filed an affidavit from the Chief Fiscal Officer of its Department of Public Aid stating that
the Department would immediately cease all activities and requests for federal reimbursement pursuant to the "Emergency Assistance" program of § 406(e) of the Social Security Act,
and that "no additional § 406(e)
federal funds [would] be drawn for the balance . . . of the current fiscal year."
In opposing the motions to dismiss, the plaintiffs argued that, even though the State would no longer request federal reimbursement for emergency aid under §§ 406(e) and 403(a)(5), it intended nonetheless to operate virtually the identical program as an AFDC "special needs" program, and to seek federal reimbursement under § 403(a)(1). They contended that such a course of conduct would be equally unlawful. The District Court took the position that the validity of any proposed program under the AFDC provisions presented a new question that had not been raised in the original lawsuit, and that the plaintiffs' challenge to the § 406(e) program had indeed been rendered moot by the State's decision to withdraw altogether from the EA program. When the plaintiffs declined to amend their complaint to allege that the new program would also be in violation of § 403(a)(1), the District Court entered an order dismissing the cause "for lack of case or controversy."
[98 S.Ct. 2073] The Court of Appeals again reversed. Mandley v. Trainor, 545 F.2d 1062 (Mandley II). Noting that the defendants
admit[ted] that they [were] conducting the same program under the label "special assistance" that they formerly conducted under the label of emergency assistance,
Id. at 1068, the Court of Appeals held that the change in funding arrangements did not raise issues beyond the scope of the...
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