The Lewis v. Martin case in 1969 involved the California Department of Social Welfare's policy that reduced Aid to Families with Dependent Children (AFDC) benefits when a "man in the house" was assumed to be contributing financially, even if he was not legally obligated to do so. The Supreme Court ruled against this policy, stating it violated the Social Security Act by assuming income without evidence and infringing on due process rights under the Fourteenth Amendment. The court held that states could only consider available income from those legally liable for child support or care – typically biological or adoptive parents – when determining AFDC eligibility and benefit levels. This decision reinforced federal standards over state policies regarding welfare distribution.

In the dissenting opinion for Lewis et al. v. Martin, Justice Harlan argued that California's regulation of Aid to Families with Dependent Children (AFDC) was not in violation of federal law or the Constitution. He contended that it is within a state’s rights to consider income from a "man in the house" when determining AFDC eligibility and benefits amount, as long as this man has an obligation under state law to support children living with him. Harlan believed that such consideration does not conflict with federal laws governing AFDC because these laws do not explicitly prohibit states from considering all available resources when calculating aid amounts. Furthermore, he asserted that there is no constitutional right guaranteeing welfare recipients will receive a certain level of benefits regardless of other potential sources of financial support.