In the case of Batterton v. Francis in 1976, the Supreme Court ruled that a state's decision to reduce welfare benefits did not violate due process rights under the Fourteenth Amendment. The Department of Human Resources in Maryland had reduced Aid to Families with Dependent Children (AFDC) payments by 14% as part of an effort to balance its budget. A group of AFDC recipients sued, arguing this reduction was arbitrary and violated their constitutional rights. However, the court held that since there were no allegations or evidence suggesting that these reductions were made for reasons unrelated to legitimate state interests such as balancing budgets or preserving fiscal integrity, they could not be considered unconstitutional.

In the dissenting opinion for Batterton v. Francis, Justice William Rehnquist argued that the majority's decision to allow welfare recipients to sue state officials over alleged violations of federal regulations was a significant expansion of judicial power. He contended that this ruling would open up a floodgate of litigation against states and their officials, potentially overwhelming courts with cases involving complex administrative law issues. Furthermore, he expressed concern about the potential financial burden on states resulting from such lawsuits. Justice Rehnquist also disagreed with the majority's interpretation of 42 U.S.C §1983 as providing a cause of action in situations where there is no constitutional violation or deprivation of rights secured by federal laws but merely an alleged violation of federal regulations.