A state’s Aid to Families with Dependent Children (AFDC) program stressed “close contact” with beneficiaries, requiring home visits by caseworkers as a condition for assistance. This rule prohibited visitation with a beneficiary outside working hours, as well as forcible entry. The defendant, a beneficiary under the AFDC program, refused to permit a caseworker to visit her home after receiving several days’ advance notice. She received notice that the government would consequently cancel her assistance.
Whether a home visitation is an unreasonable search and, when not consented to or supported by a warrant based on probable cause, would violate the defendant’s Fourth Amendment rights?
No. The home visitation provided for by law concerning the AFDC program is a reasonable administrative tool and does not violate any right guaranteed by the Fourth Amendment.
The Court held, assuming that the home visit has some of the characteristics of a traditional search, the state’s program was reasonable. The Court found multiple reasons for concluding the intrusion was reasonable. The home visit served the needs of the dependent child, it enabled the government to detect that the intended objects of the benefits were receiving them, the program stressed privacy by not unnecessarily intruding on the beneficiary’s rights in her home, provided the government with essential information not obtainable through other sources, was conducted, not by a law enforcement officer, but by a caseworker, and was not a criminal investigation. Finally, the consequence of refusal to permit a home visitation, which does not involve a search for violations, is not a criminal prosecution but only the cancellation of benefits.
400 U.S. 309, 91 S. Ct. 381 (1971)