In the case of Heckler, Secretary of Health and Human Services v. Turner et al., 1984, the Supreme Court was asked to decide on whether a state could supplement federal food stamp benefits with its own funds without violating federal law. The respondents were Ohio residents who received both food stamps and public assistance from the state. When Congress reduced federal food stamp allotments in 1981, Ohio increased its public assistance payments to offset these reductions for some recipients but not all. This led to a class-action lawsuit arguing that this violated equal protection rights under the Fourteenth Amendment as well as provisions of Social Security Act. The Supreme Court ruled in favor of Heckler (the Secretary), holding that states are not required by federal law or constitutionally mandated to make up for cuts in Federal aid programs like Food Stamps with their own resources; they can choose how much supplemental aid they provide based on their budgetary constraints and policy considerations. Furthermore, it held that there is no violation of Equal Protection Clause when different levels of supplementation are provided because such decisions involve complex social judgments which courts should be hesitant about second-guessing.

In the dissenting opinion for Heckler v. Turner, it was argued that the majority's decision failed to adequately consider the legislative intent behind Aid to Families with Dependent Children (AFDC) program. The dissenters believed that Congress intended for states to take into account both earned and unearned income when determining a family's need level under AFDC. They also disagreed with the majority’s interpretation of Section 602(a)(7), arguing that this provision should not be read in isolation but rather in conjunction with other provisions of Social Security Act which clearly indicate an intention by Congress to treat all income alike, whether earned or unearned. Furthermore, they contended that even if there were ambiguity about Congressional intent regarding treatment of different types of income, such ambiguities should be resolved in favor of poor families who are beneficiaries under AFDC program since one major purpose behind enactment of this legislation was poverty alleviation.