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Black Citizenship And Welfare BAYAN ABUBAKR

09-14-2017, 00:12 AM
bayan abubakr
<abayan abubakr
Registered: 11-01-2006
Total Posts: 18





Black Citizenship And Welfare BAYAN ABUBAKR

    11:12 PM September, 14 2017

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    Barack Obama has been accused of sympathizing with terrorists, forging a birth
    certificate, being born in Kenya, being a Muslim, and being a citizen of Indonesia. There is an
    entire Wikipedia page—currently at 11,421 words—dedicated to “Barack Obama citizenship
    conspiracy theories.” Although Obama released his birth certificate in 2008, 23% of the United
    States continued to believe that he was born in another country. Skepticism about his citizenship
    existed beyond those who disliked him: nearly 29% of people who said Obama was not born in
    the United States approved of the job he was doing as President, of whom 23% said they wanted
    to see him reelected in 2012. 1 The question of Barack Obama’s citizenship wasn’t a matter of
    politics, policy, or partisanship. It was a question of the legitimacy of a black man in the highest
    office of the United States. Being American, for a black man, is conditional on behaving like a
    “grateful guest.”2 You can stay here, sure, but in the guest room. You can stay here, sure, but you
    can’t be President. You can’t be the American, at least not while being black.
    Black Americans are treated as subjects rather than citizens. A subject “is under the
    power of another; but a citizen is a unit of a mass of free people who collectively possess
    sovereignty.”3 This has manifested itself through state and federal welfare systems: “citizens
    receive welfare as an entitlement the government has an obligation [to fund] as compensation for
    their social contribution or as a prerequisite to their participation in sociopolitical and economic
    life.”4 Subjects, on the other hand, receive “inferior, inefficient, and stigmatizing assistance at
    the government’s discretion,” and their benefits depend on their conformity to “behavioral rules
    and submission to government scrutiny and assessment.”5 Ultimately, welfare for subjects allows
    the government to rule them, as they are vulnerable to “official or quasi-official state sanctioned
    inquiry and surveillance.”6 This is accompanied by the government’s authority to investigate and
    control these persons’ behavior. For instance, some states have conditioned payments on
    mothers’ compliance with varying standards of sexual morality and have tested her deviance
    through means and morals testing. In the last thirty years, at least thirty states attempted to
    modify their welfare programs to include some form of behavior modification.7 This system of
    welfare derives from a racist, divisive, and tyrannical history.
    Modern welfare systems deny black Americans their right to privacy. This is maintained
    by the fact that they are not considered natural citizens of the United States. As an American,
    1 “Section 6: Obama, 2012, and the Tea Party,” PEW Research Center (May 4, 2011)
    2 Wesley Morris, “Colin Kaepernick and the Question of Who Gets to Be Called a ‘Patriot’” (September
    12, 2016)
    3 David Ramsay, “A Dissertation on the Manner of Acquiring the Character and Privileges of a Citizen of
    the United States,” (1789).
    4 Dorothy Roberts, “Welfare and the Problem of Black Citizenship,” (1996)
    5 Ibid.
    6 Joel Handler and Margaret Rosenheim, “Privacy in Welfare: Public Assistance and Juvenile Justice,”
    (1966).
    7 Dorothy Roberts, “The Welfare Debate: Who Pays for Procreation؟” in Killing the Black Body: Race,
    Reproduction, and the Meaning of Liberty, 226-230.
    6
    blackness is the ultimate marker of illegitimacy, and this has reinforced itself through various
    state sanctioned welfare systems. The development of welfare systems as a means of controlling
    poor individuals, families, and communities of color can be traced through four Supreme Court
    cases: Dandridge v. Williams (1970), Wyman v. James (1971), Lyng v. Castillo (1986), and
    Bowen v. Gilliard (1987).
    To be black and a citizen of the United States is to live in a paradoxical world. Blackness
    and citizenship, in the ways in which they were constructed, exist in constant tension with one
    another. Citizenship was built off the backs of people of color by and for whiteness. Whiteness is
    the defining marker of citizenship without which one cannot be considered a natural citizen of
    the United States. Citizenship is itself an abstract term, but it signifies an emergence of liberties
    specific to the United States and the modernity of the Western world. Citizenship was constituted
    and reinforced by social relations established by colonial governance in the Americas, Asia, and
    Africa. These differences made it possible for Western liberalism to theorize and practice the
    universality of human freedom, “despite the fact that freedom for slaves, colonized, and
    indigenous people were exempted by this ideology.”8 To individuals deemed worthy, citizenship
    granted them civility, and a right to privacy and intimacy.
    Citizenship grants Americans political emancipation, social equality, and the promise of
    economic freedom. Political emancipation, in particular, is a critical part of citizenship. For
    European and North American citizens in the 19th century, ideas of privacy were constituted
    within an individual’s right to political protection. This understanding of citizenship can be
    traced in the political philosophical traditions of Locke, Rousseau, Kant, and Hegel. They
    consider and analyze the modern individual, or the Western man, who possesses “interiority of
    person” as well as the private household. 9 Hegel, for example, traced the development of
    citizenship through various forms of privacy: property, family, and domestic life.10 This notion
    of privacy became critical to defining the modern liberal individual and how citizenship itself
    became a function of privacy.
    During the Progressive era, white women advocated for the universality of welfare
    systems, but made sure that black people were excluded from these systems. This was justified
    through beliefs such as: “blacks needed less to live on than whites,” and that, as one Southern
    public assistance field supervisor claimed, “the number of Negro cases is few due to the
    unanimous feeling on the part of the staff and the board that there are more work opportunities
    for Negro women.”11 The Civil Rights movement, however, began opening the welfare system to
    black Americans. It forced states to relax welfare eligibility requirements, raise benefit levels,
    and increase the availability of benefits to single-parent households. The federal government,
    under the scrutiny of the international community and civil rights activists, proceeded to set up
    several programs designed to integrate more black Americans into federal and state assistance
    programs. But this victory came with consequences. Aid to Families with Dependent Children
    (AFDC), a system of welfare administered by states with federal funding, became “increasingly
    associated with black mothers already stereotyped as lazy, irresponsible, and overly fertile. It
    became burdened with behavior modification rules, work requirements, and reduced effective
    8 Lisa Lowe, “The Intimacies of Four Continents,” in The Intimacies of Four Continents, 16-20.
    9 Ibid, 28.
    10 Ibid, 27-29.
    11 Dorothy Roberts, “The Welfare Debate: Who Pays for Procreation؟,” in Killing the Black Body: Race,
    Reproduction, and the Meaning of Liberty, 202-246.
    7
    benefit levels.”12 Furthermore, the inclusion of black Americans in welfare programs became
    stigmatized as proof of black people’s lack of work ethic, perpetual depravity, and dependency.13
    The black woman, as a result, became the state’s enemy. This black woman depleted the state’s
    resources, was a site of poverty and destitution, and tarnished the purity of “Americanness.” In
    response, welfare became a tool of social control and an entry point for the state into the lives of
    poor, black families.
    Under AFDC, the state of Maryland computed a “standard of need” for each family. In
    Maryland, this standard increased with every additional member of the family, but at the same
    time, it incrementally decreased. Rather than paying the full amount of determined need to each
    family, the state, to conserve funds, established a “ceiling of about $250 per month, regardless of
    the size of the family and its actual need.”14 This resulted in smaller families receiving “100
    percent of their state-determined minimum subsistence while larger families were receiving a
    lesser percentage, the exact percentage reduction depending upon the size of the family.”15
    Larger families were discriminated against and were more likely to starve than smaller families.
    This is invidious and explicitly prejudiced. Maryland could not direct its efforts to cap the state
    budget at larger families, as there is no compelling reason for them to do so. Larger families are
    no less justified to welfare benefits than smaller families. In its totality, this policy was designed
    to make life “more difficult for low-income families, thrust them deeper into poverty, and
    ultimately, discourage additional births.”16 This family cap, and others like it, was intended to
    prevent mothers on welfare from having additional children, as this would ultimately ease public
    burden. This sort of policy is based on the myth of the sexually irresponsible welfare queen: a
    woman of color who has multiple children to cash in on her welfare benefits. This was built off
    the premise that women should not have children if they cannot provide for them without
    welfare; considering this, children by welfare mothers were another means by which the welfare
    queen could rob the state. Family caps are an extension of a “misogynoir” stereotype.17 Capping
    welfare curbs the incentive to produce more children, supposedly putting an end to the moral
    decline and pathology in poor communities of color.
    Dandridge v. Williams (1970) punished unconventional families through the state of
    Maryland’s “standard of need.” The plaintiffs were Linda Williams, a single mother, and Junius
    and Jeanette Gary, a married couple. They were parents of eight children each. They filed a case
    against Edmund P. Dandridge, chairman of the Maryland State Board of Public Welfare, because
    Maryland’s method of calculating a “standard of need” discriminated against larger families and
    was a violation of the equal protection clause of the Fourteenth Amendment. The plaintiffs also
    claimed that the “standard of need” calculation conflicted with the stated purpose of AFDC, as
    per the Social Security Act of 1935 (“[aid] shall be furnished with reasonable promptness to all
    eligible individuals”). The District Court found that the regulation was unconventional and in
    violation of the Social Security Act. The Supreme Court, in a 5-3 decision, found that the
    Maryland provision was not unconstitutional and was not in violation of stated AFDC policies.
    The Court looked to a precedent set by King v. Smith (1968), which described AFDC as “a
    12 Ibid, 240-246.
    13 Ibid.
    14 Dandridge v. Williams, 397 U.S. 471 (1970).
    15 Mevlyn Durchslag, “Welfare Litigation, the Eleventh Amendment and State Sovereignty: Some
    Reflections on Dandridge v. Williams,” (1975).
    16 Jamelle Bouie, “The Most Discriminatory Law in the Land,” (June 17, 2014).
    17 Eliza Anyangwe, “Misogynoir: where racism and sexism meet,” (October 5, 2015).
    8
    scheme of cooperative federalism,” and granted the states “considerable latitude in allocating
    their AFDC resources, since each state is free to set its own standard of need and to determine
    the level of benefits by the number of funds it devotes to the program.”18 The Court also
    reasoned that the state, by capping welfare benefits, could encourage employment in the
    marketplace. In his dissent, Justice William Douglas warned of “the danger that the state could
    use welfare programs to ‘wield its economic whip’ over disfranchised groups, forcing them to
    dance in response to the dominant groups’ fantasies and phobias about its own Soul.”19
    Welfare caps policed welfare recipients. These caps weren't the only barriers to welfare,
    however. Caseworkers prove to be yet another means of restricting access to welfare, and they
    negatively affect the experiences of welfare recipients of color.
    Caseworker visits are an essential part of the welfare system’s oppressive and invasive
    methods. They are a form of checks and balances that ensure that the state’s money is being used
    as directed. These visits come with intrusive questions with prodding, and suspicious undertones.
    They are also laced with a systemic racial bias; “white welfare recipients benefit considerably
    from the discretionary actions of their caseworkers…black and white welfare clients may be
    incorrectly attributed to differences in work ethic, personal motivation, or attitude.”20
    Caseworkers are the intermediaries between welfare systems, relevant government agencies, and
    welfare recipients. They can help define and set the parameters of a recipient’s under welfare,
    and they have free reign in doing so. Unequal treatment at the hands of caseworkers is unfair,
    discriminatory, and reinforces the stereotype of the malicious black welfare recipient. The same
    stereotypes that drove welfare agencies to enforce means and morals testing to validate eligibility
    for welfare created the need and desire to use caseworkers as the designated gatekeepers of
    welfare. Caseworkers are another agent of surveillance that can ensure where, why, and most
    importantly, to whom welfare is being distributed. Caseworkers are a point of entry into the lives
    of poor families. When these poor families are also families of color, caseworkers become a
    point of entry, monitoring, and behavior modification. The biases that muddle a caseworker’s
    judgment can play into the benefits a recipient is eligible for. It is for this reason that welfare
    should not have to depend on caseworker visits to “verify” the legitimacy of a recipient’s claims.
    Wyman v. James (1971) was a direct and insidious violation of Barbara James’ right to
    privacy. James was a welfare recipient and single mother. After having a son, James applied for
    assistance under New York’s AFDC program. She was deemed eligible and began receiving her
    benefits after a caseworker visited her apartment. Two years later, James was scheduled to be
    visited again by another caseworker—this was required under New York state law and could
    affect James’ benefits under AFDC. James refused the caseworker’s visit because “questions
    concerning personal relationships, beliefs, and behavior are raised and pressed, which is
    unnecessary for a determination of continuing eligibility.”21 James continued to refuse the visit,
    and AFDC assistance was terminated, even though James “expressed willingness to cooperate
    and to permit the visit elsewhere.”22 James filed a claim under Section 1983 of the Civil Rights
    Act of 1971 in the District Court for the Southern State of New York. She claimed “that the
    18 King v. Smith, 392 U.S. 309 (1968).
    19 Dandridge v. Williams, 397 U.S. 471 (1970).
    20 Susan Gooden, “All Things Not Being Equal: Differences in Caseworker Support Toward Black and
    White Welfare Clients,” (1997).
    21 Wyman v. James, 400 U.S. 309 (1971).
    22 Ibid.
    9
    caseworker visit was a search,”23 and as such, would violate her Fourth and Fourteenth
    Amendment rights. The District Court ruled in her favor, the state of New York appealed, and
    the case was sent to the Supreme Court. In a 6-3 opinion, the Court found that the caseworker
    visit was not an “unreasonable search or seizure,” and therefore, was not in violation of James’
    Fourth Amendment rights. Justice Harry Blackmun, writing for the majority of the Court,
    reasoned that the visit was not forced or compelled, meaning that “there is no entry of the home
    and there is no search.”24 Furthermore, Blackmun argued the visit would allow the state to ensure
    that its welfare funds were being spent appropriately. In his dissent, Justice William Douglas
    argued that welfare was a form of surveillance:
    In this manner, welfare acted as an agent of violence; Welfare has long
    been considered the equivalent of charity and its recipients have been subjected to
    all kinds of dehumanizing experiences in the government’s efforts to police its
    welfare payments. In fact, over half a billion dollars are expended annually for
    administration and policing in connection with the Aid to Families with
    Dependent Children program. Why such large sums are necessary for
    administration and policing has never been adequately explained. No such sums
    are spent policing the government subsidies granted to farmers, airlines,
    steamship companies, and junk mail dealers… The bureaucracy of modern
    government is not only slow, lumbering, and oppressive; it is omnipresent. It pries
    more and more into private affairs…25
    Wyman v. James legitimized yet another tool of government and state-sanctioned
    surveillance. It legalized an odious and discriminatory invasion of privacy that sustained the
    notion that black Americans should be treated as subjects, always to be surveilled, rather than as
    citizens of the United States.
    In 1982, the Food Stamp Program was amended and eligibility and benefit levels in the
    program began to be determined on a “household” basis. This definition of “household” did not
    include more distant relatives or groups of unrelated persons living together. Rather, a
    “household” consisted of two parents, their children, and the parents’ siblings. Before this
    revision, the federal food stamp program evaluated eligibility on an individual basis. A group of
    individuals would be eligible for more food stamps if they consisted of several households,
    rather than just one. These amendments target a particular kind of welfare recipient, the recipient
    that does not fit into the traditional, normalized definition of a “household”: “in Lyng v. Castillo
    several families lost all or part of their food stamp benefits when adult children or siblings were
    forced to reside together…[T]he Food Stamp Program penalizes families that turn to their
    relatives for shelter.”26 Children whose income is available to a household applying for
    assistance were forced to consider moving out of their homes, refusing to help support their
    family, or surrendering their income to support their household’s chance at receiving adequate
    benefits. These amendments fall in line with other revisions to welfare programs during the late
    1980’s and early 1990’s that represented an ideological shift in response to the War on Poverty.
    This shift called for federal deregulation, criticized the welfare state, and aimed to reduce federal
    23 Ibid.
    24 Ibid.
    25 Ibid.
    26 Lyng v. Castillo, 477 U.S. 635 (1986).
    10
    aid to impoverished communities. Communities and individuals of color were scapegoated, as
    they were, by mainstream definition, the quintessence of the welfare state and how damning it
    was to American society. This is the sort of ideology that created the foundation for the statutory
    revision in question. It redefined what a “household” could legally look like for families in need
    of welfare. Through its intrusive approach to regulating funds, it treated welfare recipients like
    subjects, rather than citizens.
    Lyng v. Castillo (1986) restructured and redefined the statutory definition of a household.
    The Castillo family—the plaintiffs—consisted of a mother, a father, and their children who lived
    with the mother’s adult daughter. Although they were separate living units, the Castillos were
    denied eligibility as a separate household because they lived with an adult who already received
    food stamps. The Castillos claimed that “the statutory distinction between parents and children,
    and all other groups of individuals violates the due process clause of the Fifth Amendment.”27
    The District Court of the Southern District of Texas invalidated this distinction because it
    “directly and substantially” interfered with family living arrangements. The decision was sent to
    the Supreme Court, where the lower court’s decision was reversed; a state’s ability to define a
    “household” was found constitutional. The Court found that “Congress could reasonably
    determine that close relatives sharing a home—almost by definition—tend to purchase and
    prepare meals together while distant relatives and unrelated individuals might not be so
    inclined.” The Court also reasoned that Congress had an “undeniably legitimate desire to prevent
    fraud and waste in the food stamp program.” Justice Thurgood Marshall, in his dissent, argued
    that “the government has chosen to intrude into the family dining room…[and] what possible
    interest can the government have in preventing members of a family from dining as they
    choose؟” He claimed that there were no grounds for Congress’s assumption that related persons
    living together were a significant source of fraud. Rather, Marshall claimed that Congress
    determined that the government could save money by “tightening the definition of an eligible
    food stamp household” and scapegoating larger, more unconventional families.28 Lyng is
    discriminatory in that it doesn’t provide reasonable rationale for it targeting blended or unusual
    “households,” and in doing so, appears to directly attack the poor, “unconventional” welfare
    recipient.
    The Deficit Reduction Act of 1984 (DERFA) was an attempt by the AFDC, backed by
    Congress, to use family size as a marker for eligibility. Before 1984, families with dependent
    children applying for AFDC could exclude children with outside financial support from their
    filing. This changed with the passage of DERFA. DERFA amended the AFDC program to
    require families to include all children living in the same house in the filing, even if they had
    outside support. This meant that the total sum of AFDC benefits could be reduced by an amount
    corresponding to the sum of any child support received. DERFA served as an intrusion into
    private households and family networks. It punished families that did not operate as typical twoparent
    households: families that are blended, families with multiple parents, and families that
    don’t fit the “two-point-five-kids” mold. In America, these are families with grandmothers
    raising their grandchildren, with aunts raising their nieces and nephews, and families where
    kinship exists beyond bloodlines and biological parenthood. Although “kinship care” is common
    among all races, cultures, and ethnicities, black children are “more likely than other racial or
    27 Ibid.
    28 Ibid.
    11
    ethnic groups to live in a household without either parent and not be raised by kin.”29 DERFA
    was in reckless disregard for the privacy to which these households are entitled.
    This, however, fails to have any substantive meaning because poor people of color are
    considered subjects, rather than citizens of the state. Their homes warrant surveillance and
    intrusion because their homes are where poor people of color breed their illegitimate and toxic
    cultures, the very cultures that push them in the direction of welfare. These are families that are
    considered illegitimate because fathers don’t live with their children, and the mothers in these
    households are not always the mothers of said children. These families are looked upon
    negatively because they use the state’s money to fund their “unorthodox” lifestyles, and this is
    unacceptable. Therefore, welfare recipients––especially recipients of color who lead
    “unconventional” lifestyles––need to be monitored by the state.
    In Bowen v. Gilliard (1987), the Supreme Court found that the state may force families to
    “shrink rearrange, or break up to qualify for benefits” through DERFA.30 In 1970, Betty Mae
    Gilliard, a welfare recipient, gave birth to her second child. Since she was receiving child support
    from the child’s father, the state deducted the child support from the benefits she was eligible for
    as the parent of an eight-person household. Gilliard sued and the District Court ruled in her
    favor. The court claimed that she could exclude the child receiving child support from her filing
    unit because the seven-person family benefits were greater than what she would receive from the
    eight-person family benefits minus the child support. When North Carolina adopted the DERFA,
    Gilliard and other members of the class action filed a motion to reopen the case. They argued
    that the DERFA was a violation of the due process clause of the Fourteenth Amendment and the
    takings clause of the Fifth Amendment. The District Court ruled in Gilliard’s favor, North
    Carolina appealed the decision, and the case was sent to the Supreme Court. The Court found
    that the DERFA amendment did not violate the due process clause and its equal protection
    component because it “does not interfere with a family’s fundamental right to live in the type of
    family unit it chooses.” 31 Furthermore, the Court found that Congress’s rationale for passing
    DERFA––reducing the national deficit and distributing aid to needy families in the fairest way
    possible––was constitutional. The majority decision failed to consider how DERFA would affect
    family structures and networks once it was put into place. These ramifications were explored in
    Justice William Brennan’s dissent, where he argued that DERFA was an intrusion that was
    unprecedented, intolerable, and muddled the line between “public citizen and private person.” In
    this case, the federal government “directly and substantially interfered with family living
    arrangements.”32
    The Supreme Court played a substantial role in legitimizing stereotypes and commonly
    held beliefs of welfare recipients. These beliefs, given welfare’s racialized history, were
    projected onto the lives of people of color, and these projections fed into policy and rhetoric.
    They further reinforced the idea that welfare recipients of color were subjects of the state that
    needed to be policed, rather than citizens. These Supreme Court rulings are important because
    they shed light onto the perception of welfare during what some might argue to be its demise.
    The fall of welfare was marked by the rise of the War on Drugs and the heightened
    29 Tyreasa Washington, James P. Gleeson, and Kelly L. Rulison “Competence and African-American
    Children in Informal Kinship Care: The Role of Family,” (2013).
    30 Bowen v. Gilliard, 483 U.S. 587 (1987).
    31 A.W. Phinney III, “Feminism, Epistemology, and the Rhetoric of Law: Reading Bowen v. Gilliard,”
    (1989).
    32 Bowen v. Gilliard, 483 U.S. 587 (1987).
    12
    criminalization of the black body, the black family, and black communities. It is unsurprising, to
    say the least, that welfare became another means by which the government could target people of
    color.
    People of color have and will continue to be subjected to the tyranny of the United States.
    They are not natural citizens of the United States. They created citizenship, but citizenship was
    not created for them. Welfare is based on this notion, and it has, and will continue to, operate on
    the body of the black subject.
    BIBLIOGRAPHY
    Anyangwe, Eliza. “Misogynoir: where racism and sexism meet.” The Guardian, October 5,
    2015. https://www.theguardian.com/lifeandstyle/2015/oct/05/what-is-misogynoir
    Bouie, Jamelle. “The Most Discriminatory Law in the Land.” Slate, June 17, 2014.
    http://www.slate.com/articles/news_and_politics/politics/201...ximum_family_grant_a
    nd_family_caps_a_racist_law_that_punishes_the.html
    Durchslag, Melvyn R. “Welfare Litigation, the Eleventh Amendment and State Sovereignty:
    Some Reflections on Dandridge v. Williams.” Case Western Reserve Law Review 26, no. 1
    (1975): 60-100.
    Gleeson, James P., Kelly L. Rulison, and Tyreasa Washington. “Competence and AfricanAmerican
    Children in Informal Kinship Care: The Role of Family.” Children and Youth Services
    Review 35, no. 9 (2013): 1305-12.
    Gooden, Susan. “All Things Not Being Equal: Differences in Caseworker Support Toward Black
    and White Welfare Clients.” Harvard Journal of African-American Public Policy 4 (1997): 23-
    33.
    Handler, Joel, and Margaret Rosenheim. “Privacy in Welfare: Public Assistance and Juvenile
    Justice.” Law and Contemporary Problem 31 (1966): 377-412.
    Lowe, Lisa. The Intimacies of Four Continents. Durham: Duke University Press, 2015.
    Morris, Wesley. “Colin Kaepernick and the Question of Who Gets to Be Called a ‘Patriot’” The
    New York Times Magazine, September 12, 2016.
    https://www.nytimes.com/2016/09/18/magazine/who-gets-to-be-called-a-patriot.html
    Phinney III, A.W. “Feminism, Epistemology, and the Rhetoric of Law: Reading Bowen v.
    Gilliard.” Harvard Women’s Law Journal 12 (1989): 151-80.
    Ramsay, David. “A Dissertation on the Manner of Acquiring the Character and Privileges of a
    Citizen of the United States.” Evans Early American Imprint Collection, 1789.
    http://quod.lib.umich.edu/cgi/t/text/text-idx؟c=evans;idno=N17114.0001.001http://quod.lib.umich.edu/cgi/t/text/text-idx؟c=evans;idno=N17114.0001.001
    Roberts, Dorothy E. “Welfare and the Problem of Black Citizenship” (1996). Faculty
    13
    Scholarship. Paper 1283. http://scholarship.law.upenn.edu/faculty_scholarship/1283/http://scholarship.law.upenn.edu/faculty_scholarship/1283/
    —. Killing the Black Body: Race, Reproduction, and the Meaning of Liberty. New York:
    Penguin Random House, 1998.
    “Section 6: Obama, 2012, and the Tea Party,” Pew Research Center, May 4, 2011.
    http://www.people-press.org/2011/05/04/section-6-obama-2012-and-the-tea-party/
    Dandridge v. Williams, 397 U.S. 471 (1970).
    Bowen v. Gilliard, 483 U.S. 587 (1987).
    Lyng v. Castillo, 477 U.S. 635 (1986).
    Wyman v. James, 400 U.S. 309 (1971).
    King v. Smith, 392 U.S. 309 (1968).
                  

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