In the case of Otis R. Bowen, Secretary of Health and Human Services v. Mary Alice Galbreath (1987), the United States Supreme Court addressed whether a state could consider both parents' income when determining Medicaid eligibility for a child living with one parent but receiving financial support from another. The court ruled in favor of Bowen, stating that federal law allows states to count only the income of family members who live together when assessing Medicaid eligibility. Therefore, it was deemed inappropriate for Ohio to include child support payments from an absent father as part of his children's "income" when deciding their eligibility for medical assistance under Title XIX (Medicaid) program.

In the dissenting opinion of Bowen v. Galbreath, Justice Blackmun argued that the majority's decision was inconsistent with Congress' intent when it enacted Social Security Act provisions regarding child's insurance benefits. He believed that the court had misinterpreted these provisions and failed to consider their legislative history properly. According to him, Congress intended for children who were dependent on a disabled parent at any time before they turned 18 years old to be eligible for benefits if their parent became entitled to disability insurance after they reached adulthood but before turning 22 years old. The majority’s interpretation would exclude many deserving individuals from receiving benefits simply because their parents did not become disabled until after they had turned 18 years old, which he felt was contrary to Congressional intent.