Chapman v. Houston Welfare Rights Organization

In Chapman v. Houston Welfare Rights Organization (1979) U.S. 99 S.Ct. 1905, 60 L.Ed.2d 508, a decision construing the jurisdictional counterpart of section 1983, 28 U.S.C. 1343(3) & (4), the Supreme Court discussed the scope of section 1983 in the context of a suit to redress an alleged conflict between state welfare regulations and the Federal Social Security Act. Four members of the Court expressed the view that section 1983 provided a cause of action to redress a deprivation of the kind of federal statutory rights involved in the case. (Chapman v. Houston Welfare Rights Organization, supra, U.S. at 99 S.Ct. 1905 (White, J., concurring in judgment), 99 S.Ct. 1905 (Stewart, J., dissenting).) Three members of the Court were of the opinion that section 1983 did not provide a cause of action for the deprivation of such statutory rights. (Chapman v. Houston Welfare Rights Organization, supra, U.S. at 99 S.Ct. 1905 (Powell, J., concurring).) Two members of the Court did not reach the issue because they held, for the plurality, that even if section 1983 provided a cause of action, there was no jurisdiction under 28 U.S.C. 1343(3) or (4). In Chapman the Supreme Court held that because a suit to redress an alleged conflict between state welfare regulations and the Federal Social Security Act was not a suit based on a statute providing for equal rights or for the protection of civil rights, there was no jurisdiction under sections 1343(3) & (4). The court majority did not reach the question whether section 1983 provided a cause of action for such a suit, although four members of the Court indicated that they would answer that question in the affirmative, while three members of the Court indicated that they would give a negative answer to that question.