Price v. Cohen
United States Court of Appeals for the Third Circuit
715 F.2d 87 (1983)
- Written by Samantha Arena, JD
Facts
Under the Pennsylvania Public Welfare Code (the code), all individuals eligible for general assistance received payments for 12 months per year. However, the legislature passed § 10 of the code, which established two categories of needy individuals receiving different benefit amounts: the chronically needy and the transitionally needy. The chronically needy, including children under 18, adults over 45, and others in specific need categories, continued to receive assistance each month. In contrast, the transitionally needy individuals between 18 and 45 who did not otherwise fall into a chronically needy category were eligible for general-assistance benefits for only three months per year. Pennsylvania justified the change as an effort to reallocate limited welfare funds more effectively, to encourage those who were physically capable of working to become independent, and to combat fraud. Individuals deemed transitionally needy under § 10 (transitionally needy individuals) (plaintiffs) sought an injunction against Walter Cohen (defendant), the secretary of the Pennsylvania Department of Public Welfare (DPW), contending that the statute violated the Fourteenth Amendment Equal Protection Clause because it discriminated among similarly situated individuals based on age. The district court enjoined DPW from enforcing § 10. Cohen appealed.
Rule of Law
Issue
Holding and Reasoning (Adams, J.)
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