Those precise questions have not been decided in the Supreme Court or in the Fourth Circuit. In Doe v. Klein, 599 F.2d 338 (9th Cir. 1979), plaintiff had applied for AFDC benefits provided by the State of Idaho. Plaintiff had so done when she was 16, unmarried, pregnant and living at home with her parents. Her parents were seemingly ineligible for AFDC benefits as to their daughter.
It is unclear whether jurisdiction was properly invoked under 28 U.S.C. § 1343. See Chapman v. Houston Welfare Rights Org., 441 U.S. 600, 99 S.Ct. 1905, 60 L.Ed.2d 508 (1979); Doe v. Klein, 599 F.2d 338 (9th Cir. 1979). Nevertheless, the amount in controversy exceeds $10,000 and so the district court did clearly have federal question jurisdiction ( 28 U.S.C. § 1331).
In reviewing a statute subject to the standards set forth in Salfi, "unless a classification is `patently arbitrary' or `utterly lacking in rational justification', there is no due process violation." Doe v. Klein, 599 F.2d 338, 340 (9th Cir. 1979). The Supreme Court since Salfi has reemphasized the distinction between statutes regulating fundamental rights, for which irrebuttable presumptions may be deemed violative of due process, and statutes regulating economic matters, for which statutory irrebuttable presumptions are to be judged under a "rational justification" standard of review.
It is undisputed that § 1983 is a remedial statute which provides a civil cause of action for state deprivation of federal statutory or constitutional rights. Chapman v. Houston Welfare Rights Organization, 441 U.S. 600, 99 S.Ct. 1905, 60 L.Ed.2d 508 (1979); Estate of Himelstein v. Ft. Wayne, 898 F.2d 573 (7th Cir. 1990); Doe v. Klein, 599 F.2d 338 (9th Cir. 1979); Gonzales v. Young, 560 F.2d 160 (3rd Cir. 1977). As a remedial statute, § 1983 is to be broadly construed by the courts.