In Bowen, Secretary of Health and Human Services v. Gilliard et al., the U.S Supreme Court upheld a federal law that required families to include all members' income when determining eligibility for food stamps. The case was brought by several North Carolina families who argued that the requirement violated their Fifth Amendment rights to due process and equal protection under the law because it forced them into involuntary servitude by making them financially responsible for relatives they did not wish to support. However, in a 5-4 decision, the court ruled against these claims stating that Congress had broad discretion in setting welfare policy and could reasonably decide to consider all family income when awarding benefits. The court also rejected arguments that this policy interfered with familial privacy or created an unconstitutional condition on receipt of public assistance.

In the dissenting opinion for Bowen, Secretary of Health and Human Services v. Gilliard et al., Justice Brennan argued that the majority's decision violated principles of federalism by allowing Congress to impose its definition of "family" on states administering their own welfare programs. He contended that this imposition infringed upon a state’s right to define family in accordance with local values and traditions. Furthermore, he believed it was an overreach for Congress to require all members of a household receiving Aid to Families with Dependent Children (AFDC) benefits be included in one filing unit regardless if they were financially independent or not. This requirement could potentially reduce overall aid received by families as income from non-dependent members would count towards total family income, possibly pushing them above eligibility thresholds. Brennan also expressed concern about potential privacy violations due to increased scrutiny into familial financial arrangements.