In the case of Linda J. Blessing, Director, Arizona Department of Economic Security v. Cathy Freestone, Etc., et al., 1996, the Supreme Court ruled that a group of mothers could not sue an Arizona state agency for failing to provide timely child support services as required by federal law. The plaintiffs argued that they were entitled to these services under Title IV-D of the Social Security Act and sought enforcement through Section 1983 - a statute allowing individuals to sue government officials for violating their constitutional rights or other federal laws. However, the court held in a unanimous decision that while Title IV-D created obligations binding on states participating in its programs (like providing certain child support services), it did not confer individual rights enforceable under Section 1983 because it lacked unambiguous intent from Congress to do so.

In the dissenting opinion for Blessing v. Freestone, Justice Stevens argued that the majority's decision was too narrow in its interpretation of whether individuals have a federal right to sue under Title IV-D of the Social Security Act. He believed that Congress intended to create individual rights when it enacted this law and thus, private citizens should be able to enforce these rights through lawsuits if necessary. Furthermore, he disagreed with the majority's view that there is no "unambiguous" intent by Congress to confer such rights because he felt that language used in other parts of Title IV-D clearly indicates an intention on behalf of lawmakers for individuals to benefit from its provisions. Therefore, according to Justice Stevens' dissenting opinion, Arizona’s failure to substantially comply with federal requirements could constitute a violation of those individual rights.