Quern v. Mandley
Annotate this Case
436 U.S. 725 (1978)
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U.S. Supreme Court
Quern v. Mandley, 436 U.S. 725 (1978)
Quern v. Mandley
Argued November 30, 1977
Decided June 6, 1978
436 U.S. 725
This litigation originated as a challenge to the validity of Illinois' Emergency Assistance to Needy Families with Children (EA) program under Title IV-A of the Social Security Act (SSA). The Court of Appeals, reversing the District Court, first held that the program was invalid because it limited eligibility for such assistance more narrowly than § 406(e)(1) of the SSA, which makes federal matching funds available under a state EA program for emergency aid to intact families with children if threatened with destitution, regardless of the cause of the need. In a later appeal involving the validity of a proposed alternative to the EA program, the Court of Appeals held that § 403(a)(5) of the SSA, which authorizes federal funding of a state EA program, is the exclusive source of federal funds for a state program of emergency assistance, and that therefore a new "special needs" program that Illinois proposed to operate under its Title IV-A Aid to Families with Dependent Children (AFDC) program, funded under § 403(a)(1) of the SSA, in place of its withdrawn EA program, must, as a de facto EA program, extend aid to all persons eligible under § 406(e)(1).
1. There is nothing in the policies or history of the EA statute to indicate that Illinois' proposed "special needs" program should not be judged solely under the requirements for an AFDC program funded under § 403(a)(1) without regard to the EA requirements of §§ 406(e) and 403(a)(5). Pp. 436 U. S. 735-736.
2. The proposed "special needs" program is permissible as part of an AFDC program alone. A plan to meet certain emergency needs of AFDC recipients -- specifically actual or threatened loss of shelter due to damage or eviction -- is not necessarily improper as an AFDC "special needs" program simply because it addresses a nonrecurring need that could alternatively be provided for under an EA program. Pp. 436 U. S. 737-739.
3. Neither § 402(a)(10) of the SSA, which makes AFDC, not EA, eligibility criteria mandatory, nor § 406(e), which defines the permissible
scope of an EA program for purpose of federal funding, imposes mandatory eligibility standards on States that elect to participate in the EA program, and therefore Illinois is not precluded from receiving matching federal funds for either an EA or a "special needs" program simply because it limits eligibility for aid under that program more narrowly than § 406(e). Pp. 436 U. S. 739-747.
545 F.2d 1062, reversed and remanded.
STEWART, J., delivered the opinion of the Court, in which all other Members joined except BLACKMUN, J., who took no part in the consideration or decision of the cases.