In the 1994 case Eloise Anderson, Director, California Department of Social Services, et al. v. DeShawn Green, Debby Venturella and Diana P. Bertollt, etc., the U.S Supreme Court addressed a dispute over welfare benefits for children in foster care or living with relatives other than their parents under Aid to Families with Dependent Children (AFDC). The plaintiffs argued that California's policy of reducing AFDC payments when federal Supplemental Security Income (SSI) was also being received violated the Social Security Act by treating SSI as income available to the child's family unit rather than solely for the child’s use. The court ruled in favor of Anderson and upheld California's policy on grounds that it did not violate federal law because SSI is intended to cover a recipient’s basic needs and any excess can be considered part of family income.

The dissenting opinion in the case of Eloise Anderson, Director, California Department of Social Services v. DeShawn Green et al., argued that the majority's decision to uphold a state law requiring welfare recipients to live in California for at least one year before receiving full benefits was unjust and unconstitutional. The dissenters believed this ruling violated the Equal Protection Clause by discriminating against new residents based on their length of residency. They contended that it is unfair to deny these individuals equal access to public assistance simply because they have not lived in the state for a certain period. Furthermore, they disagreed with the majority's assertion that such laws serve legitimate state interests like preventing welfare fraud or encouraging fiscal responsibility. Instead, they saw them as punitive measures aimed at discouraging poor people from moving into the state.