Shea v. Vialpando - 416 U.S. 251 (1974)
U.S. Supreme Court
Shea v. Vialpando, 416 U.S. 251 (1974)
Shea v. Vialpando
Argued February 26, 1974
Decided April 23, 1974
416 U.S. 251
Section 402(a)(7) of the Social Security Act requires state agencies in administering the Aid to Families with Dependent Children (AFDC) program to "take into consideration . . . any expenses reasonably attributable to the earning of . . . income." Such expenses are deducted from an AFDC applicant's income in determining eligibility for assistance. Colorado's AFDC regulations, which previously had permitted the deduction from income of all expenses reasonably attributable to employment, including transportation expenses, were amended in 1970 to subject work-related expenses (with certain exceptions) to a uniform allowance of $30 per month. This substantially reduced respondent's monthly deductions for work-related transportation expenses and the corresponding increase in her monthly net income made her ineligible for continued AFDC assistance. She then brought this action for injunctive and declaratory relief, claiming, inter alia, that Colorado's standardized work expense allowance violated § 402(a)(7). The District Court granted summary judgment for respondent, and the Court of Appeals affirmed.
Held: The Colorado regulation conflicts with § 402(a)(7), and is therefore invalid. Pp. 416 U. S. 258-266.
(a) In light of the statute's legislative history and the normal meaning of the term "any," the language of § 402(a)(7) requiring the consideration of "any" reasonable work expenses in determining eligibility for AFDC assistance is to be interpreted as a congressional directive that no limitation, apart from that of reasonableness, may be placed upon recognition of work-related expenses, and hence a fixed work expense allowance that does not permit deductions for expenses exceeding that standard directly contravenes the language of the statute. P. 416 U. S. 260.
(b) Standardized treatment of work-related expenses without provision for showing actual and reasonable expenses exceeding the standard amount threatens to defeat the purpose of the
mandatory work expense recognition provision of § 402(a)(7) of encouraging AFDC recipients to secure and retain employment, since, by limiting work expenses to $30 per month, the Colorado regulation results in a disincentive to seek or retain employment for all recipients whose reasonable work-related expenses exceed or would exceed that amount. Pp. 416 U. S. 263-265.
(c) It is not the adoption of a standardized work expense allowance per se that violates § 402(a)(7), but the fact that the standard is, in effect, a maximum or absolute limitation upon the recognition of such expenses. P. 416 U. S. 265.
475 F.2d 731, affirmed.
POWELL, J., delivered the opinion for a unanimous Court.