The U.S. Supreme Court case Atkins, Commissioner, Massachusetts Department of Public Welfare v. Rivera et al., 1985 revolved around the issue of welfare benefits for families with dependent children where one parent is unemployed. The state of Massachusetts had a policy that limited these benefits to those families in which the principal wage earner was unemployed due to circumstances beyond their control (e.g., layoffs or illness), but not when they were out of work by choice or because they couldn't find employment after quitting a job without good cause. The respondents, two mothers who were denied aid under this policy, challenged it as violating federal law and the Equal Protection Clause. In its decision, the Supreme Court upheld Massachusetts' policy. It ruled that there was no violation since federal law did not require states to provide assistance in all cases where parents are unemployed; instead it allowed them discretion on how best to use available resources within broad guidelines set by Congress. Furthermore, it found no equal protection violation because classifications based on unemployment status are subject only to rational basis review - meaning they need only be rationally related to legitimate government interests - and here there was a reasonable fit between Massachusetts' chosen means and its goal of encouraging parental responsibility.

In the dissenting opinion for Atkins v. Rivera, Justice Rehnquist argued that the majority's decision to strike down Massachusetts' method of calculating welfare benefits was incorrect. He contended that the state's formula was not arbitrary or capricious and did not violate federal law, as it took into account both income and expenses when determining a family’s eligibility for assistance. Furthermore, he asserted that this case should have been dismissed because there were no allegations of any actual harm suffered by the plaintiffs due to their reduced benefits. In his view, they had failed to demonstrate standing - a necessary requirement in order for them to bring suit against Massachusetts Department of Public Welfare Commissioner Atkins.