Supreme Court of the United States

Blessing v. Freestone

April 21, 1997520 U.S. 329

Summary

Justice O'Connor, writing for a unanimous Court, held that Title IV–D does not confer an individual federal right to compel a State's substantial compliance with its child-support enforcement requirements. Courts must evaluate specifically identified statutory rights rather than treat Title IV–D as an undifferentiated whole. The Court also held that the statute's administrative enforcement scheme does not foreclose § 1983 enforcement of any individual rights particular provisions might create. It vacated the Ninth Circuit's judgment and directed further proceedings to identify and evaluate the mothers' specific claims. Justice Scalia, joined by Justice Kennedy, concurred, reserving whether beneficiaries of federal-state spending agreements may ever enforce those agreements under § 1983.

Holding

  • Individual enforcement of substantial compliance with Title IV–D.. Title IV–D does not give individuals a federal right to force a state agency to substantially comply with the program's requirements.
  • Identification of statutory rights enforceable under § 1983.. Plaintiffs must identify particular statutory rights, and courts must evaluate each asserted right separately rather than recognize unspecified rights under Title IV–D as a whole.
  • Individual rights under systemwide data-processing and staffing requirements.. The discussed data-processing standards and requirements for sufficient agency staffing do not create individually enforceable federal rights.
  • Implicit displacement of § 1983 by Title IV–D's enforcement scheme.. Title IV–D's administrative enforcement provisions are not sufficiently comprehensive to foreclose § 1983 enforcement of any individual rights the statute may create.

Docket 95-1441

Cited authorities

  • Rule 14.1(a)
  • 42 U.S.C. §§ 601-617
  • CA11
  • 88 Stat. 2351
  • 42 U.S.C. §§ 651
  • 42 U.S.C. § 1983
  • 42 U.S.C. §§ 601-617
  • 42 U.S.C. §§ 651

Cited by

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