Anderson v. Edwards

• Decision Date: 22 March 1995
• Docket Number: 931883
• Citation: 115 S.Ct. 1291,131 L.Ed.2d 178,514 U.S. 143
• Parties: Eloise ANDERSON, Director, California Department of Social Services, et al., Petitioners v. Verna EDWARDS, etc., et al
• Court: U.S. Supreme Court

514 U.S. 143

115 S.Ct. 1291

131 L.Ed.2d 178

Eloise ANDERSON, Director, California Department of Social Services, et al., Petitioners

v Verna EDWARDS, etc., et al.

No. 93-1883.

Supreme Court of the United States

Argued Jan. 18, 1995.

Decided March 22, 1995.

Syllabus ^*

The federal "family filing unit rule," 42 U.S.C. § 602(a)(38), requires that all cohabiting nuclear family members be grouped into a single "assistance unit" (AU) for purposes of eligibility and benefits determinations under the Aid to Families with Dependent Children (AFDC) program. California's "non-sibling filing unit rule" (California Rule) additionally groups into a single AU all needy children who live in the same household, whether or not they are siblings, if there is only one adult caring for them. When application of the California Rule resulted in decreases in the maximum per capita AFDC benefits due respondents, who include Verna Edwards and her cohabiting dependent minor granddaughter and two grandnieces, they brought this action for declaratory and injunctive relief against petitioners, the state officials charged with administering California's AFDC program, claiming that the California Rule violates federal law. The District Court granted summary judgment for respondents, and the Court of Appeals affirmed.

Held: Federal law does not prohibit California from grouping into a single AU all needy children living in the same household under the care of one relative. Pp. __.

(a) The California Rule does not violate 45 CFR § 233.20(a)(2)(viii), an AFDC regulation prohibiting States from reducing the amount of assistance "solely because of the presence in the household of a non-legally responsible individual." Respondents are simply wrong when they contend that, e.g., it was solely the arrival in Mrs. Edwards' home of her grandnieces that triggered a decline in the per capita benefits that previously were paid to her granddaughter; rather, it was the grandnieces' presence plus their application for AFDC assistance through Mrs. Edwards. Had the grandnieces, after coming to live with Mrs. Edwards, either not applied for assistance or applied through a different caretaker relative living in the home, the California Rule would not have affected the granddaughter's benefits at all. Pp. __.

(b) Nor does the California Rule violate 45 CFR §§ 233.20(a)(2)(viii), 233.20(a)(3)(ii)(D), and 233.90(a)(1), which prohibit States from assuming that a cohabitant's income is available to a needy child absent a case-specific determination that it is actually or legally available. First, the California Rule does not necessarily reduce the benefits of all needy children when one of them receives outside income, for California may rationally assume that the caretaker will observe her duties to all of the AU's members and will take into account the receipt of any such income by one child when expending funds on behalf of the AU. Second, the California Rule simply authorizes the combination of incomes of all AU members in order to determine the amount of the AU's assistance payment. This accords with the very definition of an AU as the group of individuals whose income and resources are considered "as a unit" in determining the amount of benefits, 45 CFR § 206.10(b)(5), and is authorized by the AFDC statute itself, 42 U.S.C. § 602(a)(7)(A), which provides that a state agency "shall, in determining need, take into consideration any . . . income and resources of any child or relative claiming [AFDC assistance]." In light of the great latitude that States have in administering their AFDC programs, see, e.g., Dandridge v. Williams, 397 U.S. 471, 478, 90 S.Ct. 1153, 1158, 25 L.Ed.2d 491, that statute is reasonably construed to allow States, in determining a child's need (and therefore the amount of her assistance), to consider the income and resources of all cohabiting children and relatives also claiming assistance. The availability regulations are addressed to an entirely different problem: Attempts by States to count income and resources controlled by persons outside the AU for the purpose of determining the amount of the AU's assistance. See 42 Fed.Reg. 6583-6584, and, e.g., King v. Smith, 392 U.S. 309, 88 S.Ct. 2128, 20 L.Ed.2d 1118. The California Rule has no such effect. Pp. __.

(c) Respondents' alternative arguments—(1) that the federal family filing unit rule occupies the field and thereby pre-empts California from adopting its Rule, and (2) that the California Rule violates 45 CFR § 233.10(a)(1) and § 233.20(a)(1)(i), which require equitable treatment among AFDC recipients—lack merit. Pp. __.

12 F.3d 154, reversed and remanded.

THOMAS, J., delivered the opinion for a unanimous Court.

Dennis Paul Eckhart, Sacramento, CA, for petitioners.

Paul A. Engelmayer, New York, for the U. S., as amicus curiae by sp. leave of the Court.

Katherine Meiss, Los Angeles, CA, for respondents.

Justice THOMAS delivered the opinion of the Court.

This case presents the question whether federal law governing the Aid to Families with Dependent Children (AFDC) program prohibits States from grouping into a single AFDC "assistance unit" all needy children who live in the same household under the care of one relative. Such grouping allows States to grant equal assistance to equally sized needy households, regardless of whether the children in the household are all siblings. The Court of Appeals for the Ninth Circuit concluded that federal law forbids States to equalize assistance in this manner. We disagree and accordingly reverse.

I

AFDC is a joint federal-state public assistance program authorized by Title IV-A of the Social Security Act, 49 Stat. 627, 42 U.S.C. § 601 et seq. As its name indicates, the AFDC program "is designed to provide financial assistance to needy dependent children and the parents or relatives who live with and care for them." Shea v. Vialpando, 416 U.S. 251, 253, 94 S.Ct. 1746, 1750, 40 L.Ed.2d 120 (1974). The program "reimburses each State which chooses to participate with a percentage of the funds it expends," so long as the State "administer[s] its assistance program pursuant to a state plan that conforms to applicable federal statutes and regulations." Heckler v. Turner, 470 U.S. 184, 189, 105 S.Ct. 1138, 1141, 84 L.Ed.2d 138 (1985) (citing 42 U.S.C. §§ 602, 603).

One applicable federal rule requires state plans to provide that all members of a nuclear family who live in the same household must apply for AFDC assistance if any one of them applies; in addition, the income of all of these applicants must be aggregated in determining their eligibility and the amount of their monthly benefits. See 42 U.S.C. § 602(a)(38) (1988 ed., Supp. V); 45 CFR § 206.10(a)(1)(vii) (1993). See generally Bowen v. Gilliard, 483 U.S. 587, 107 S.Ct. 3008, 97 L.Ed.2d 485 (1987) (upholding rule against constitutional challenges). This "family filing unit rule" requires that all cohabiting nuclear family members be grouped into a single AFDC "assistance unit" (AU), defined by federal law as "the group of individuals whose income, resources and needs are considered as a unit for purposes of determining eligibility and the amount of payment." 45 CFR § 206.10(b)(5) (1993). The regulation at issue in this case California's "non-sibling filing unit rule" (California Rule)—goes even further in this regard. It provides: "Two or more AUs in the same home shall be combined into one AU when . . . [t]here is only one [adult] caretaker relative." Cal. Dept. of Social Servs., Manual of Policies & Procedures § 82-824.1.13, App. to Pet. for Cert. 52. In other words, the California Rule groups into a single AU all needy children who live in the same household, whether or not they are siblings, if there is only one adult caring for all of them.

The consolidation of two or more AU's into a single AU pursuant to the California Rule results in a decrease in the maximum per capita AFDC benefits for which the affected individuals are eligible. This occurs because while California (like many States) increases the amount of assistance for each additional person added to an AU, the increase is not proportional. Thus, as the number of persons in the AU increases, the per capita payment to the AU decreases.¹ See, e.g., Dandridge v. Williams, 397 U.S. 471, 473-474, 90 S.Ct. 1153, 1155-56, 25 L.Ed.2d 491 (1970) (sustaining a Maryland AFDC regulation under which "the standard of need increases with each additional person in the household, but the increments become proportionately smaller").

The situation of respondent Verna Edwards and her relatives illustrates the operation of these two rules. Initially, Mrs. Edwards received AFDC assistance on behalf of her granddaughter, for whom she is the sole caretaker.² As a one-person AU, the granddaughter was eligible to receive a "maximum aid payment" of $341 per month prior to September 1991. See n. 1, supra. Later, Mrs. Edwards began caring for her two grandnieces, who are siblings. Pursuant to the federal family filing unit rule, the grandnieces are grouped together in a two-person AU, which was eligible to receive $560 per month in benefits prior to September 1991. See ibid. Because none of these children received any outside income, Mrs. Edwards received $901 per month in AFDC assistance on behalf of the three girls. In June 1991, however, Mrs. Edwards received notice that pursuant to the California Rule, her granddaughter and two grandnieces would be grouped together into a single three-person AU, which was eligible to receive only $694 per month. See ibid. The California Rule thus reduced AFDC payments to the Edwards household by $207 per month.

On behalf of themselves and others similarly situated, Mrs. Edwards, her three relatives, and other respondents brought this action against petitioners, the state officials charged with administering California's AFDC program, in the District Court for the Eastern District of California. Pursuant...