Williams ex rel. Ricard v. Humphreys

125 F. Supp. 2d 881 (2000)

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Williams ex rel. Ricard v. Humphreys

United States District Court for the Southern District of Indiana
125 F. Supp. 2d 881 (2000)

Facts

The federal government offered a program that assisted states in providing public assistance to families in need, Temporary Assistance to Needy Families (TANF). Under a TANF rule, states using TANF aid had to require families receiving TANF funds to assign any child-support payments collected by the family to the state as a means of offsetting the TANF funds received. The Supreme Court had upheld the requirement to assign child-support payments against challenges. For example, the Supreme Court upheld the assignment provision in a state that allowed the child to keep a portion of the child-support payments and also actually provided TANF funds on behalf of the child to the family in exchange. However, Indiana enacted this benefit program in a manner that made it subject to an alleged violation of the Takings Clause of the United States Constitution as applicable to the states via the Fourteenth Amendment. In Indiana, a needy family received TANF benefits for each child in the family, except for any children who were born 10 months after the family started to receive benefits. These children were excluded from the benefits, but Indiana still required that any child-support payments the custodial parent received from a noncustodial parent be assigned to the state. A plaintiff class of these excluded children brought suit against Katherine Humphreys (defendant), an Indiana official in her official capacity. The named plaintiff, Cameron Williams (plaintiff), asserted that Indiana’s policy of requiring a child who did not receive benefits to turn over child-support payments to the state to offset the cost of the benefits received by the child’s family was an unconstitutional taking of the child’s private property to support a public purpose without providing just compensation. Indiana argued that the state had a right to retain the child-support payments of an excluded child until the amount collected in child support was equivalent to the TANF benefits the state had given an excluded child’s family. Each party filed a motion for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Hamilton, J.)

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