Bearden v. Georgia, 461 U.S. 660 (1983): The U.S. Supreme Court considered the issue of whether a convicted felon could have his probation revoked as a result of not being able to pay his fine. In this case, the petitioner had only a ninth grade education, could not read, and was unable to find a job. The Court ruled that the trial court improperly revoked the felon’s probation because it did not make a determination as to whether the petitioner had made “bona fide efforts to pay” the fine. The Court ruled that assuming there are alternative methods of punishing a probationer besides imprisonment or a fine, probation can only be revoked if the probationer either “willfully refused to pay the fine or restitution when he has the means to pay” or “failed to make sufficient bona fide efforts to seek employment or borrow money in order to pay the fine or restitution.”
Dandridge v. Williams, 397 U.S. 471 (1970): The U.S. Supreme Court considered the validity of Maryland's Aid to Families With Dependent Children statute and whether its "maximum grant" provision complied with the Social Security Act of 1935 and the Equal Protection Clause. Maryland's "maximum grant" rule capped monthly benefits for families at $250 regardless of family size. Maryland stated that its rule was justified insofar as it encouraged employment, incentivized family planning, and provided funding to the maximum number of families. The Supreme Court held that the Social Security Act did not require that "the 'aid' furnished must equal the total of each individual's standard of need in every family group," but only that "some aid was provided to all eligible families and all eligible children;" moreover, the court held that there was a "reasonable basis" for the "maximum grant" provision, and therefore, it did not violate the Equal Protection Clause.
Development of Housing & Urban Development v. Rucker, 535 U.S. 125 (2002): The U.S. Supreme Court considered an eviction statute, which required public housing agencies to include drug-related eviction provisions in all leases. The statute expressed that "any drug-related" activity was "grounds for [eviction]." Tenants contended that they were not subject to eviction under the statute when they were unaware of their non-tenant guest's drug activity. However, the Supreme Court held that the statute "unambiguously requires lease terms that vest local public housing authorities with the discretion to evict tenants for the drug-related activity of household members and guests whether or not the tenant knew, or should have known, about the activity."
Douglas v. California, 372 U.S. 353 (1963): The U.S. Supreme Court considered whether an indigent defendant has a right to have counsel appointed during the defendant's first appeal as a matter of right. Bennie Meyes and William Douglas were charged with thirteen felonies, including robbery, assault with a deadly weapon, and assault with intent to commit murder. Both were indigent and represented by a single public defender. The public defender "moved for a continuance stating that the case was very complicated, that he was not as prepared as he felt he should be . . . and that there was a conflict of interest between the petitioners requiring the appointment of separate counsel for each of them." His motions were denied. Meyes and Douglas dismissed their public defender and renewed the motions for a continuance and separate counsel. Again, the motions were denied. Subsequently, Meyes and Douglas were jointly tried and convicted of all thirteen felonies. They each appealed as of right and requested the assistance of counsel on appeal. This was also denied. The Supreme Court noted that states can "provide for differences [among citizens] so long as the result does not amount to a denial of due process or an 'invidious discrimination.' Absolute equality is not required." However, "where the merits of the one and only appeal an indigent has as of right are decided without benefit of counsel," the Court found that "an unconstitutional line has been drawn between rich and poor." Here, the Court held that denial of counsel on appeal was unconstitutional under the Fourteenth Amendment.
Gideon v. Wainwright, 372 U.S. 335 (1963): The U.S. Supreme Court determined whether the Sixth Amendment's right to counsel applied to the states. An inmate was charged with a felony under Florida law. "Appearing in court without funds and without a lawyer," the inmate asked the court to appoint counsel for him. His request was denied because, under state law, only a defendant charged with a capital offense was entitled to appointed counsel. Thus, the inmate represented himself at trial and was ultimately convicted and sentenced to five years in state prison. He "attack[ed] his conviction and sentence on the ground that the trial court's refusal to appoint counsel for him denied him rights 'guaranteed by the Constitution and the Bill of Rights[.]'" On writ of certiorari, the Supreme Court reviewed the text and application of the Sixth Amendment: "The Sixth Amendment provides, 'In all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of Counsel for his defence.' We have construed this to mean that in federal courts counsel must be provided for defendants unable to employ counsel unless the right is competently and intelligently waived." Then, recognizing that "any person haled into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided for him," the Supreme Court ruled that the right to counsel is so fundamental and essential to a fair trial" that it should be "made obligatory upon the states by the Fourteenth Amendment."
Goldberg v. Kelly, 397 U.S. 254 (1970): The U.S. Supreme Court decided whether the termination of "public assistance payments to a particular recipient without affording him the opportunity for an evidentiary hearing prior to termination denie[d] the recipient procedural due process in violation of the Due Process Clause of the Fourteenth Amendment." A group of New York residents receiving aid under the federally assisted programs, Aid to Families with Dependent Children (AFDC) or New York State's general Home Relief program, alleged that termination of aid without "prior notice and hearing" denied them of their right to due process. While the Supreme Court noted that "some governmental benefits may be administratively terminated without affording the recipient a pre-termination evidentiary hearing," the Court found that for situations where "welfare is discontinued, only a pre-termination evidentiary hearing provides the recipient with procedural due process." Indeed, welfare is necessary to "obtain essential food, clothing, housing, and medical care," and thus, termination of benefits while the issue was pending deprived recipients of the "very means by which to live while he waits." Moreover, the Court found that affording recipients a pre-termination evidentiary hearing fulfills the governmental interest of "foster[ing] the dignity and well-being of all persons within its borders."
Harper v. Virginia State Board of Elections, 383 U.S. 663 (1966): The U.S. Supreme Court considered whether a state required poll tax for residents twenty-one years of age and older violated the Equal Protection Clause of the Fourteenth Amendment. The Virginia Constitution directed the General Assembly to levy an annual poll tax not exceeding $1.50 on every resident of the state twenty-one years of age and older. Harper, a Virginia resident, brought suit against the Virginia State Board of Elections, alleging that the Virginia poll tax violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court held that the Equal Protection Clause was indeed violated "whenever it makes the affluence of the voter or payment of any fee an electoral standard." The Court noted, "[t]he principle that denies the State the right to dilute a citizen's vote on account of his economic status or other such factors by analogy bars a system which excludes those unable to pay a fee to vote or who fail to pay. . . . [W]ealth or fee paying has . . . no relation to voting qualifications; the right to vote is too precious, too fundamental to be so burdened or conditioned." Thus, the Virginia poll tax violated the Equal Protection Clause.
Inclusive Communities Project v. Lincoln Property Company, 920 F.3d 890 (5th Cir. 2019): The Fifth Circuit considered disparate treatment and disparate impact claims under the Fair Housing Act against owners and management companies of apartment complexes in the greater Dallas area that declined to participate in the federal Section 8 Housing Choice Voucher Program. However, the complaint failed to allege facts sufficient to provide causation necessary for an actionable claims. The Court reviewed the Federal Rule of Civil Procedure 12(b)(6) standard, noting that dismissal of a claim under 12(b)(6) is warranted if "the complaint does not contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face.'" Here, the Court found the allegations of disparate treatment to be "vague and conclusory," and thus, the claim was "legally insufficient to support a reasonable inference of intentional race discrimination." Additionally, the complaint did not allege sufficient facts showing disparate impact because the data cited did not support an inference that a "'no vouchers policy' caused black persons to be the dominant group of voucher holders in the Dallas metro area . . . . or that defendants [bore] any responsibility for the geographic distribution of minorities throughout the Dallas area."
Kadrmas v. Dickinson Public Schools, 487 U.S. 450 (1988): The U.S. Supreme Court considered whether a family living below the poverty level in rural North Dakota was denied equal protection as a result of a school bus fee when the family lived nearly twenty miles from their daughter's school and could not afford the fee. The family claimed that the bus fees violated the Equal Protection Clause. However, the Supreme Court found that "[t]he Constitution does not require that such [bus] service[s] be provided at all," nevermind "for free." Moreover, the Court rejected applying strict scrutiny given that the Supreme Court has not previously "accepted the proposition that education is a 'fundamental right . . . .'" Therefore, the bus fee did not deprive students of the right to education.
Lassiter v. Department of Social Services, 452 U.S. 18 (1981): The U.S. Supreme Court considered whether a right to counsel exists outside the scope of criminal proceedings. On a motion to terminate a mother's parental rights, the mother was not represented by counsel. Her parental rights were subsequently terminated, and the child was placed in the custody of the Department of Social Services. The mother contended that "because she was indigent, the Due Process Clause of the Fourteenth Amendment entitled her to the assistance of counsel." The Court ruled that there is a "presumption that an indigent litigant only has a right to appointed counsel when, if he loses, he may be deprived of his physical liberty." Analyzing the Mathews v. Eldridge factors (see below), the Supreme Court ruled that an individual's interests could overcome the presumption against the right to appointed counsel in some appropriate cases. However, applying those factors, the Court held that the trial court did not violate the mother's due process rights by not appointing counsel for her in her termination of parental rights proceeding.
Mathews v. Eldridge, 424 U.S. 319 (1976): The U.S. Supreme Court considered whether a public employee was denied procedural due process when he did not receive a hearing prior to termination of his Social Security disability benefit payments. A three-part test emerged to determine whether an administrative procedure met the constitutional guarantees of the Due Process Clause. First, the Supreme Court considered "the private interest that will be affected by the official action[.]" Second, they considered "the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards[.]" Third, they considered "the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail." The Court found that procedural due process had been satisfied because "the disabled worker's need is likely to be less than that of a welfare recipient[,]" and "[t]he potential value of an evidentiary hearing . . . is substantially less in this context" than in welfare cases like Goldberg (see above). Lastly, the Court found that additional procedures to protect disability benefits would create an "incremental cost resulting from the increased number of hearings and the expense of providing benefits to ineligible recipients pending decision."
San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973): The U.S. Supreme Court considered whether the Fourteenth Amendment was violated by a system of financing public education based on neighborhood property taxes. Mexican-American parents brought a class action suit against the San Antonio Independent School District on behalf of schoolchildren throughout the state who were members of minority groups or resided in poor neighborhoods. The suit was in response to a financing system that funded teacher salaries, school operating expenses, and transportation costs from taxes within each district. Given that the property values were lower in plaintiffs' district compared to richer neighborhoods, there was less money collected to fund educational expenses for plaintiffs. Thus, plaintiffs alleged that the stark disparity in public funding and quality of education among school districts violated the Equal Protection Clause. The Supreme Court analyzed the financing scheme under rational basis review, reasoning that education was not a fundamental right. Under rational basis review, there need only be a rational relationship between a "legitimate state purpose" and the state regulation. Thus, the discrepancy in school funding between schools financed by low versus high property tax bases did not amount to a constitutional violation because the financing scheme bore a rational relation to "assuring a basic education for every child in [Texas] . . ."
Sanchez v. County of San Diego, 464 F.3d 916 (9th Cir. 2006): The Ninth Circuit considered whether administrative home visits for welfare verification purposes were reasonable under the Fourth Amendment. San Diego County required welfare applicants to consent to home visits as a condition of eligibility for benefits. As part of the mandatory home visit, each applicant was subject to an interview and a home walk-through. Any evidence in plain view of a potential crime during the walk-through would be reported. San Diego County welfare applicants challenged the home-visit requirement as a violation of the Fourth Amendment’s protection against unreasonable searches. The Ninth Circuit found that the home visits served "the important governmental interests of verifying an applicant's eligibility for welfare benefits and preventing fraud." Moreover, imposing a "warrant requirement would pose serious administrative difficulties" in the welfare context and make "home visits more intrusive" because the warrants could be executed with force and without notice, and therefore, "welfare applicants' rights and privacy would be subject to greater infringement." Lastly, even if the home visits constituted searches -- which the Court said they did not in Wyman (see below) -- the visits were reasonable because the visitors were "not uniformed officers" and "only enter[ed] the applicant's home with consent."
United States Department of Agriculture v. Moreno, 413 U.S. 528, 93 S. Ct. 2821 (1973): The U.S. Supreme Court considered whether the termination of food stamp benefits for households "containing an individual who is unrelated to any other member of the household" violated the Due Process Clause of the Fifth Amendment. The Food Stamp Act excluded households with "unrelated" household members from participation in the food stamp program. Moreno lived with Sanchez and Sanchez's three children, none of whom she was related to. While Moreno met all income and other requirements for receiving food stamps, her benefits were denied per the household rule. Moreno brought suit against the United States Department of Agriculture (USDA) seeking to enjoin enforcement of the act. The Supreme Court held that the "unrelated person" provision was "irrelevant to the stated purpose of the [Food Stamp] Act because relationships among persons constituting one economic unit and sharing cooking facilities have nothing to do with their abilities to stimulate the agricultural economy by purchasing farm surpluses, or with their personal nutritional requirements." Rather, the provision "exclude[d] from participation in the food stamp program, not those persons who are 'likely to abuse the program' but, rather, only those persons who are so desperately in need of aid that they cannot even afford to alter their living arrangements so as to retain their eligibility." (emphasis in original).
West Coast Hotel Company v. Parrish, 300 U.S. 379, 57 S. Ct. 578 (1937): The U.S. Supreme Court considered whether a state could regulate the minimum wage paid to female employees. Washington state passed a law which regulated the minimum wages paid to female and minor employees. Elsie Parrish was employed as a maid by the West Coast Hotel Company. Parrish brought suit under the Washington law to recover back wages, i.e. the difference between the wages she was paid by West Coast Hotel Company and the minimum wage fixed under the state law. The Supreme Court found that the state had a valid interest in "the health of women and their protection from unscrupulous and overreaching employers[.]" Thus, Washington state was "entitled to adopt measures to reduce the evils of the 'sweating system,'" in which women were not paid adequate wages. Washington’s minimum wage law was upheld.
Wyman v. James, 400 U.S. 309 (1971): The U.S. Supreme Court considered whether New York's conditioning the receipt of welfare benefits under the Aid to Families With Dependent Children (AFDC) program upon a home visit conducted by social services violated an individual’s Fourth Amendment right to protection from unreasonable searches in their home. The purpose of the visits was to verify that funds were dispensed properly. Barbara James, a single mother of a newborn, applied for AFDC benefits. These benefits were granted, and a social-services employee visited her home in accordance with the program requirements. Two years later, social services attempted to conduct a biannual home visit of her home, which was a requirement for the continuation of benefits. James refused the requests for a home visit, and social services eventually terminated her benefits as a result. James filed a lawsuit, alleging a denial of her Fourth and Fourteenth Amendment rights. The Court held that the home visitation requirement did not violate any constitutional rights because the home visit was not a search under the Fourth Amendment, nor was it unreasonable. Specifically, the home visits were not performed "by police or uniformed authority[,]" were not concerned with "crime or with the actual or suspected perpetrators of crime[,]" and were "not . . . criminal investigation[s.]" Moreover, the visits are necessary to "assure verification of actual residence or of actual physical presence in the home, which are requisites for AFDC benefits[.]"
Southern Poverty Law Center Case Docket
This resource provides links to information on important civil rights cases related to poverty law. Can be filtered to specifically show landmark cases or active cases. (SPLC)