Dandridge v. Williams: Equal Protection and Welfare Law

Introduction

Dandridge v. Williams represents a reversal in the line of recent cases exemplified by King v. Smith and Shapiro v. Thompson, which declared invalid state statutes denying “eligible individuals” the right to receive payments under the Aid to Families with Dependent Children Program (AFDC). In Dandridge, the Supreme Court held that the State of Maryland’s maximum grant regulation is a permissible device under AFDC for limiting welfare payments, and that this regulation does not constitute a denial of equal protection under the fourteenth amendment of the Constitution.

The specific regulation challenged in Dandridge v. Williams, places a ceiling on the amount of assistance received by any family participating in the Maryland AFDC program. The initiators of the suit were AFDC recipients with large families. Their standard of need exceeded the, maximum level of benefits granted under the Maryland AFDC formula. They instituted the action under 42 U.S.C. §1983 to enjoin the application of the Maryland maximum grant regulation on the grounds that it is in conflict with the Social Security Act of 1935, and violates the Equal Protection Clause of the fourteenth amendment.

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