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Three factors determine whether a particular statutory provision gives rise to a federal right. First, Congress must have intended that the provision in question benefit plaintiff. Second, plaintiff must demonstrate that the right assertedly protected by the statute is not so vague and amorphous that its enforcement would strain judicial competence. Third, the statute must unambiguously impose a binding obligation on the states. In other words, the provision giving rise to the asserted right must be couched in mandatory rather than precatory terms.
Respondents, five Arizona mothers whose children are eligible for state child support services under Title IV-D of the Social Security Act, filed this 42 U.S.C. § 1983 suit against petitioner, the director of the state child support agency, claiming, among other things, that they properly applied for child support services; that, despite their good faith efforts to cooperate, the agency never took adequate steps to obtain child support payments for them; that these omissions were largely attributable to staff shortages and other structural defects in the State's program; and that these systemic failures violated their individual rights under Title IV-D to have all mandated services delivered in substantial compliance with the title and its implementing regulations. They requested broad relief, including a declaratory judgment that the Arizona program's operation violates Title IV-D provisions creating rights in them that are enforceable through a § 1983 action, and an injunction requiring the director to achieve substantial compliance with Title IV-D throughout all programmatic operations. The District Court granted summary judgment for petitioner, but the Ninth Circuit reversed. Without distinguishing among the numerous provisions of the complex Title IV-D program or the many rights those provisions might have created, the latter court held that respondents had an enforceable individual right to have the State achieve "substantial compliance" with Title IV-D. It also disagreed with the District Court's conclusion that Congress had foreclosed private Title IV-D enforcement actions by authorizing the Secretary of Health and Human Services (Secretary) to audit and cut off funds to States whose programs do not substantially comply with Title IV-D's requirements.
Did the Social Security Act's Title IV-D (42 USCS 651 et seq.) on child support enforcement programs give individuals the federal right, enforceable in 42 USCS 1983 action, to force state agencies to substantially comply with Title IV-D?
The court vacated ruling for respondents and remanded. The court disagreed that the statutory scheme could be analyzed so generally, and held that Title IV-D did not give individuals a federal right to force a state agency to substantially comply with Title IV-D. The district court had to construe the complaint in order to determine exactly what rights, considered in their most concrete, specific form, respondents were asserting. It was not apparent that respondents sought any relief more specific than a declaration that their rights were violated and an injunction forcing petitioner to substantially comply with Title IV-D.