EDELMAN V. JORDAN
415 U.S. 651 (1974)
NATURE OF THE CASE: This was a dispute over a court order for a state to dispense
retroactive benefits.
FACTS: Respondent, Jordan (P), filed a complaint in the United States District Court for
the Northern District of Illinois, individually and as a representative of a class, seeking
declaratory and injunctive relief against two former directors of the Illinois Department of
Public Aid, the director of the Cook County Department of Public Aid, and the comptroller of
Cook County. P alleged that these state officials were administering the federal-state
programs of Aid to the Aged, Blind, or Disabled (AABD) in a manner inconsistent with various
federal regulations and with the Fourteenth Amendment to the Constitution. The Department of
Health, Education, and Welfare (HEW), which administers these payments for the Federal
Government, issued regulations prescribing maximum permissible time standards within which
States participating in the program had to process AABD applications. Those regulations,
originally issued in 1968, required, at the time of the institution of this suit, that
eligibility determinations must be made by the States within 30 days of receipt of
applications for aid to the aged and blind, and within 45 days of receipt of applications
for aid to the disabled. For those persons found eligible, the assistance check was required
to be received by them within the applicable time period. P charged that the Illinois
defendants, operating under those regulations, were improperly authorizing grants to
commence only with the month in which an application was approved and not including prior
eligibility months for which an applicant was entitled to aid under federal law. The
complaint also alleged that the Illinois defendants were not processing the applications
within the applicable time requirements of the federal regulations; specifically, respondent
alleged that his own application for disability benefits was not acted on by the Illinois
Department of Public Aid for almost four months. Such actions of the Illinois officials were
alleged to violate federal law and deny the equal protection of the laws. P's prayer
requested declaratory and injective relief, and specifically requested 'a permanent
injunction enjoining the defendants to award to the entire class of plaintiffs all AABD
benefits wrongfully withheld.' The District Court granted a permanent injunction requiring
compliance with the federal time limits for processing and paying AABD applicants. It
ordered the state officials to 'release and remit AABD benefits wrongfully withheld to all
applicants for AABD in the State of Illinois who applied between July 1, 1968 [the date of
the federal regulations] and April 16, 1971. [the date of the preliminary injunction issued
by the District Court] and were determined eligible . . . .' Ds contend that the Eleventh
Amendment barred the award of retroactive benefits, that the judgment of inconsistency
between the federal regulations and the provisions of the Illinois Categorical Assistance
Manual could be given prospective effect only, and that the federal regulations in question
were inconsistent with the Social Security Act itself. The Court of Appeals rejected these
contentions and affirmed the judgment of the District Court.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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