New Yorks Aid to Families with Dependent Children (AFDC) program, stressing close contact with beneficiaries, requires home

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New York’s Aid to Families with Dependent Children (AFDC) program, stressing “close contact” with beneficiaries, requires home visits by caseworkers as a condition for assistance “in order that any treatment or service tending to restore [beneficiaries] to a condition of self support and to relieve their distress may be rendered and . that assistance or care may be given only in such amount and as long as necessary.” Visitation with a beneficiary, who is the primary source of information to welfare authorities about eligibility for assistance, is not permitted outside working hours, and forcible entry and snooping are prohibited. The appellee was a beneficiary under the AFDC program. Although she had received several days’ advance notice, she refused to permit a caseworker to visit her home. Following a hearing and advice that assistance would consequently be terminated, she brought suit for injunctive and declaratory relief, contending that home visitation is a search and, when not consented to or supported by a warrant based on probable cause, would violate her Fourth and Fourteenth Amendment rights. The district upheld the appellee’s constitutional claim. Was the district court correct? Why or why not?

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