Maine v. Thiboutot

448 U.S. 1 (1980)

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Facts

Lionel and Joline Ps, are married and have eight children, three of whom are Lionel's by a previous marriage. The Maine Department of Human Services notified P that, in computing the Aid to Families with Dependent Children (AFDC) benefits to which he was entitled for the three children exclusively his, it would no longer make allowance for the money spent to support the other five children, even though Lionel is legally obligated to support them. Ps exhausted their state administrative remedies and then sought judicial review. Ps brought a complaint in Superior Court alleging a deprivation of welfare benefits under the federal Social Security Act, 42 U.S.C. § 602(a)(7), and a civil rights violation under 42 U.S.C. §1983 for themselves and others similarly situated. The Superior Court's judgment enjoined Ds from enforcing the challenged rule and ordered them to adopt new regulations. The court denied Ps' motion for attorney's fees. The Supreme Judicial Court of Maine concluded that Ps had no entitlement to attorney's fees under state law, but were eligible for attorney's fees pursuant to the Civil Rights Attorney's Fees Awards Act of 1976, 90 Stat. 2641, 42 U. S. C. § 1988. The Supreme Court granted certiorari.

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