Anderson v. Edwards, 514 U.S. 143, 9 (1995)

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Cite as: 514 U. S. 143 (1995)

Opinion of the Court

principle, we conclude that the federal regulations do not preclude the adoption of the California Rule.


According to 233.20(a)(2)(viii), States may not reduce the amount of assistance for which AFDC applicants are eligible "solely because of the presence in the household of a non-legally responsible individual." Using the example of Mrs. Edwards and her relatives, respondents observe that, although the granddaughter received AFDC benefits of $341 per month before the two grandnieces came to live in Mrs. Edwards' household, she received only one-third of $694, or $231.33, per month after the grandnieces arrived and the California Rule took effect. See Brief for Respondents 6, 22. This reduction in the granddaughter's per capita benefits occurred, according to respondents, "solely because of the presence in the household of" the grandnieces, who are "non-legally responsible individual[s]" in relation to the granddaughter.

Respondents are simply wrong. It was not solely the presence of the grandnieces that triggered the decline in per capita benefits paid to the granddaughter; rather, it was the grandnieces' presence plus their application for AFDC assistance through Mrs. Edwards. Had the two grandnieces, after coming to live in Mrs. Edwards' home, either not applied for assistance or applied through a different caretaker relative living in that home, the California Rule would not have affected the granddaughter's benefits at all.5

5 Although needy children will receive less in per capita benefits under the California Rule, this reduction affects only children who share a household. California is simply recognizing the economies of scale that inhere in such living arrangements. See, e. g., Bowen v. Gilliard, 483 U. S. 587, 599 (1987) (crediting " 'the common sense proposition that individuals living with others usually have reduced per capita costs because many of their expenses are shared' " (quoting Termini v. Califano, 611 F. 2d 367, 370 (CA2 1979))).


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