The Burns v. Alcala case of 1974 revolved around the constitutionality of a provision in Iowa's Aid to Families with Dependent Children (AFDC) program that reduced benefits for families who had an unrelated adult living in the household. The Supreme Court ruled against this provision, stating it was unconstitutional as it violated the Equal Protection Clause of the Fourteenth Amendment. The court argued that there was no rational basis for assuming that an unrelated adult would contribute financially to a family and thus reduce their need for aid from AFDC. Furthermore, they noted such assumption could lead to unfair treatment towards certain families based on their living arrangements rather than actual financial needs.

In the dissenting opinion for Burns v. Alcala, Justice William O. Douglas argued that the majority's decision to uphold Iowa's residency requirement for welfare benefits was a violation of equal protection rights under the Fourteenth Amendment. He contended that such requirements unfairly discriminate against poor people who are often forced to move frequently due to economic circumstances beyond their control and thus may not meet residency criteria in times of need. Furthermore, he asserted that these laws serve no legitimate state interest as they do nothing more than arbitrarily deny assistance based on duration of residence rather than actual need or eligibility. In his view, this contradicts the very purpose of public assistance programs which is to provide aid for those most vulnerable in society regardless of where they live.