Blessing v. Freestone

Under the Aid to Families with Dependent Children (AFDC) program, the federal government provided funds to states to help needy families obtain necessities. AFDC required that a state’s child-support-enforcement program satisfy Title IV-D of the Social Security Act. If a state did not substantially comply with Title IV-D, its AFDC funds could be reduced by 5 percent. To substantially comply with Title IV-D, among other things, a state needed to satisfy 75 percent of its child-support-enforcement obligations. Title IV-D contained no private remedy for aggrieved individuals. Arizona participated in the AFDC program. However, Arizona obtained regular child-support payments for fewer than 5 percent of requesting parents. Cathy Freestone and other Arizona parents seeking enforcement of child-support obligations (the custodial parents) (plaintiffs) sued the director of the Arizona Department of Economic Security, Linda Blessing (defendant), in federal district court under 42 U.S.C. § 1983. The complaint alleged that Arizona had violated the custodial parents’ federal rights by failing to substantially comply with Title IV-D. The district court granted summary judgment to Arizona. The United States Court of Appeals for the Ninth Circuit reversed, holding that the custodial parents had a federal right to have Arizona substantially comply with Title IV-D. The United States Supreme Court granted certiorari.