Aughe v. Shalala

Dallas Loghry was a high-school student who suffered from a learning disability. Valerie Aughe (plaintiff), Loghry’s mother, received Aid for Families with Dependent Children (AFDC) from the Washington Department of Social and Health Services (department) (defendant). AFDC was a welfare program that provided monetary assistance to the families of needy children. Children had to satisfy certain eligibility requirements in order for their families to receive AFDC benefits. For instance, AFDC benefits were provided for children between 18 and 19 years of age only if those children were expected to finish high school before their nineteenth birthday (age requirement). The age requirement was designed to preserve AFDC funds, thereby ensuring the fiscal viability of the program. When Loghry turned 18, the department terminated AFDC benefits because Loghry was not expected to finish high school before his nineteenth birthday. Aughe appealed the termination of benefits, which was upheld by an administrative-law judge. Subsequently, Aughe filed suit in federal court, contending that the Americans with Disabilities Act (ADA) required the department to waive the age requirement as a reasonable modification for Loghry. The department filed a motion for summary judgment. The district court took the motion under advisement.