Brown v. Lukhard

In this declaratory judgment proceeding in equity, recipients of Aid to Dependent Children (ADC) benefits seek adjudication that a State departmental regulation was invalid because it violated legislative enactments. The basic question is whether certain statutory provisions, when read with portions of a biennial appropriations act, are clear and unambiguous, thus precluding use of unpublished legislative history to construe the enactments.

The ADC program is a joint federal-state effort established under the Social Security Act to provide funds to children of indigent families. In Virginia,…