Bowen v. Gilliard (1986)
- Docket
- 86-509
- Decided
- 1986-01-01
Summary
Question: Does the Deficit Reduction Act of 1984, which requires a family’s eligibility for federal aid to take into account all incomes of all family members living in the same home, violate the Fifth Amendment? Conclusion: No. Justice John Paul Stevens delivered the opinion of the 6-3 majority. The Court held that the 1984 Act supported the federal government’s dual interests of reducing the deficit and distributing aid to needy families in the fairest way possible. Because some families receive income from sources other than the government, the Court held that it was reasonable for the government to be able to provide more aid to those families that have no other means of support. Based on the rational basis for this decision, the 1984 Act did not violate the Due Process Clause. The Court also held that the 1984 Act did not violate the Takings Clause because the amount of money the child receives does not change, regardless of the amount of money the family as a whole receives from the government. The government is not taking anything away from the child without compensation, the type of government action the Takings Clause was meant to prevent. Justice William J. Brennan, Jr. wrote a dissent where he argued that the government’s actions unduly harm the parent-child relationship. Because an increasing number of children live in a single-parent household headed by the mother, forcing the children to forego the financial support of the father in order to live with the mother and receive her government benefits can cut children off from a relationship with their fathers. He argued that the 1984 Act places an undue burden on the child and the familial relationship, which requires a higher level of scrutiny than merely proving the decision was a rational one. Justice Thurgood Marshall joined in the dissent. Justice Harry A. Blackmun also wrote a dissent stating that he agreed with Justice Brennan’s arguments.