Bowen v. Gilliard

In Bowen v. Gilliard, the 6-3 U.S. Supreme Court applied the undemanding rational basis review to uphold a congressional amendment to the Deficit Reduction Act of 1984, 98 Stat. 494, by which Congress required that a family's eligibility for benefits under Federal Aid to Families with Dependent Children (AFDC) must take "into account, with certain specified exceptions, the income of all parents, brothers, and sisters living in the same home." This decision was written by Justice John Paul Stevens.

The Court rejected the argument that this "requirement violates the Fifth Amendment to the United States Constitution when it is applied to require a family wishing to receive AFDC benefits to include within its unit a child for whom child support payments are being made by a noncustodial parent." Bowen v. Gilliard, 483 U.S. 587, 589-90 (1987).

This decision is a useful precedent for when a standard of review higher than rational basis is appropriate.:

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"The disadvantaged class is that comprised by parents, children, and siblings. Close relatives are not a 'suspect' or 'quasi-suspect' class. As a historical matter, they have not been subjected to discrimination; they do not exhibit obvious, immutable, or distinguishing characteristics that define them as a discrete group; and they are not a minority or politically powerless. See, e. g., Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 313-314 (1976) (per curiam). In fact, quite the contrary is true. "Nor does the statutory classification 'directly and substantially' interfere with family living arrangements and thereby burden a fundamental right. Zablocki v. Redhail, 434 U.S. 374, 386-387, and n. 12 (1978). See id., at 403-404 (STEVENS, J., concurring); Califano v. Jobst, 434 U.S. 47, 58 (1977)." Id., at 638. In light of this, we concluded in Lyng that the "District Court erred in judging the constitutionality of the statutory distinction under 'heightened scrutiny.'"

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Bowen v. Gill, 483 U.S. at 602-03.