Bowen v. Public Agencies Opposed to Social Sec. Entrapment

In Bowen v. Public Agencies Opposed to Social Sec. Entrapment, 477 U.S. 41, 52, 106 S.Ct. 2390, 2396, 91 L.Ed.2d 35 (1986), the Court held that a termination clause in a contract between the Secretary of Health and Human Services and the State of California was superseded when Congress amended the Social Security Act to prohibit states from terminating such contracts. The Court reasoned that since the agreement by its express terms was entered into "in conformity with" the Social Security Act, without expressly protecting California from future legislation, Congress had reserved not only the right to amend the Act, but also the right to amend the individual contracts under the Act. Id. at 53, 106 S.Ct. at 2397. Furthermore, the Court was reluctant to "surrender a sovereign power ... that serves to implement a comprehensive social welfare program affecting millions of individuals throughout our Nation." Id. at 53, 106 S.Ct. at 2397.