Anderson v. Edwards, 514 U.S. 143 (1995)

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OCTOBER TERM, 1994

Syllabus

ANDERSON, DIRECTOR, CALIFORNIA DEPARTMENT OF SOCIAL SERVICES, et al. v. EDWARDS, guardian ad litem for EDWARDS, et al.

certiorari to the united states court of appeals for the ninth circuit

No. 93-1883. Argued January 18, 1995—Decided March 22, 1995

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. 149-158.

(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. P. 151.

143

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