Philbrook v. Glodgett
Annotate this Case
421 U.S. 707 (1975)
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U.S. Supreme Court
Philbrook v. Glodgett, 421 U.S. 707 (1975)
Philbrook v. Glodgett
Argued March 24-25, 1975
Decided June 9, 1975
421 U.S. 707
Under the Aid to Families with Dependent Children (AFDC) program of the Social Security Act (Act), the term "dependent child" was expanded to include children whose deprivation was caused by a parent's unemployment. Section 407(b)(2)(C)(ii) of the Act, as amended in 1968, makes this expanded definition applicable only if a state plan under the AFDC program denies aid to a dependent child so defined "with respect to any week for which such child's father receives unemployment compensation." Vermont, to qualify for federal funding under this unemployed father program, promulgated a regulation under its participating Aid to Needy Families with Children (ANFC) program, defining an "unemployed father" as one who is, inter alia, out of work, provided "[h]e is not receiving Unemployment Compensation during the same week as assistance is granted." Appellees, who are parents and children of Vermont families whose ANFC assistance was terminated or denied because the fathers were receiving unemployment compensation, filed suit against appellant Commissioner of the Vermont Department of Social Welfare and appellant Secretary of Health, Education, and Welfare to enjoin enforcement of the federal statute and state regulation. Holding that it had jurisdiction over the parties under 28 U.S.C. § 1343(3), and construing § 407(b)(2)(C)(ii) as making actual payment of, rather than mere eligibility for, unemployment compensation the disqualifying factor for AFDC benefits, a three-judge District Court held that the Vermont regulation could not be applied so as to conflict with this construction of the federal statute, and entered an injunction to this effect.
1. The Vermont regulation, as applied to exclude unemployed fathers who are merely eligible for unemployment compensation
from receiving ANFC benefits, impermissibly conflicts with § 407(b)(2)(C)(ii), as correctly interpreted by the District Court. As evidenced by that provision's legislative history, Congress did not intend the provision's coverage to be at the State's discretion once it elected to participate. Pp. 421 U. S. 713-719.
2. This Court will not inquire into the question whether the District Court had jurisdiction over appellant Secretary, but will make an exception to the general rule that this Court has a duty to so inquire where the question has been inadequately briefed, the substantive issue has been decided in the State's case, and the Secretary has stated he will comply with the District Court decision on the statutory issue if it is affirmed. The exercise of the District Court's jurisdiction over the Secretary has resulted in no adjudication on the merits that could not have been just as properly made without the Secretary, and in no issuance of process against the Secretary that he has properly contended to be wrongful before this Court. Pp. 421 U. S. 720-722.
368 F.Supp. 211, No. 73-1820, affirmed; No. 7132, dismissed.
REHNQUIST, J., delivered the opinion for a unanimous Court.