Anderson v. Lyng

644 F. Supp. 1372
CourtDistrict Court, M.D. Alabama
DecidedSeptember 26, 1986
DocketCiv. A. 85-T-1350-N
StatusPublished
Cited by12 cases

This text of 644 F. Supp. 1372 (Anderson v. Lyng) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Lyng, 644 F. Supp. 1372 (M.D. Ala. 1986).

Opinion

MEMORANDUM OPINION

MYRON H. THOMPSON, District Judge.

This class action lawsuit is a challenge to the “voluntary quit” regulation promulgated by the Secretary of the U.S. Department of Agriculture under the Food Stamp Act, 7 U.S.C.A. §§ 2011-2029. 1 The Food Stamp Act provides that an entire household is ineligible to participate in a state food stamp program for 90 days if the “head of household” voluntarily quits any job without good cause. 7 U.S.C.A. § 2015(d)(l)(B)(ii). In contrast, the regulation promulgated by the Secretary pursuant to this statutory provision substitutes “primary wage earner” for “head of household” and, accordingly, provides that the household is ineligible if the primary wage earner voluntarily quits any job without good cause. 7 C.F.R. § 273.7(n). Plaintiffs Hessie Anderson and Frankie Martin, whose households were disqualified from receiving food stamps under the regulation, *1373 claim that the regulation conflicts with the Food Stamp Act. The defendants are Richard Lyng, Secretary of the U.S. Department of Agriculture, and Gwendolyn Williams, Commissioner of the Alabama Department of Pensions and Security.

This cause is now before the court on the plaintiffs’ request that the court declare that the Secretary’s voluntary quit regulation impermissibly conflicts with the Food Stamp Act. 2 For reasons that follow, the court concludes that the plaintiffs’ request should be granted.

I.

The modern food stamp program was started in the early 1960’s to address the widespread hunger and malnutrition problem in our society. 7 U.S.C.A. § 2011. Most recently, according to Congress, there has been a “significant worsening” of this problem, especially with regard to children. H.R.Rep. No. 99-271, Part 1, 99th Cong., 1st Sess., reprinted in 1985 U.S.Code Cong. & Ad. News 1103, 1234-35.

A.

Under the food stamp program, food coupons, commonly referred to as food stamps, are used to supplement the food buying power of eligible low-income households. The program allows an eligible household to obtain from an administering governmental agency a sufficient number of food stamps to provide the household with a nutritionally adequate diet; the household then uses the stamps, along with its own money, to purchase food at retail stores. The federal government later redeems the stamps at face value. 7 U.S. C.A. §§ 2013-2025. The food stamp program is administered by state public assistance agencies under the supervision of the United States Department of Agriculture’s Food and Nutrition Service. 7 U.S.C.A. § 2020; 7 C.F.R. §§ 271.3, 271.4.

Recipients of food stamps under the Food Stamp Act must meet both financial and non-financial requirements. Among the non-financial requirements are various conditions relating to employment. With these employment requirements, Congress sought to limit the program to those who were truly needy by encouraging applicants and participants who were capable of working to do so. As a House Committee recognized in 1970, “it is still desirable for those who can do so to work in order to support themselves and their families.” H.R.Rep. No. 91-1402, 91st Cong., 2nd Sess., reprinted in 1970 U.S.Code Cong. & Ad. News 6025, 6034.

These employment requirements have a dual focus: they focus on each participating member of a household as well as on the entire household itself. For example, unless exempted, an individual member of a household may not participate in the food stamp program unless he or she registers for employment and participates in employment and training programs, and accepts certain employment, if offered. 7 U.S.C.A. § 2015(d)(1)(A) & (d)(2). In contrast, as already noted, an entire household is ineligible to participate in the program for 90 days “if the head of the household voluntarily quits any job without good cause.” 7 U.S.C.A. § 2015(d)(l)(B)(ii). With this voluntary quit provision, Congress sought to place increased emphasis “on providing benefits to those who are unable to provide for themselves and less to those, such as in this situation, who have made themselves ‘needy.’ ” Senate Rep. No. 97-504, 97th Cong., 2nd Sess., reprinted in 1982 U.S. Code Cong. & Ad.News 1641, 1677 (emphasis in original).

In an attempt to implement this statutory voluntary quit provision, 7 U.S.C.A. § 2013(c), the Secretary of Agriculture promulgated a regulation that, as already noted, defines head of household as the household’s primary wage earner. The regulation provides that “No household whose primary wage earner voluntarily quit his or her most recent job without *1374 good cause” shall be eligible to participate in the food stamp program. 7 C.F.R. § 273.7(n). Primary wage earner is defined as “that household member age 18 or over who was acquiring the greatest amount of earned financial support for the household at -the time of quit.” § 273.-7(n)(l)(iv). 3

B.

In 1985, the Alabama Department of Pensions and Security, the state public assistance agency responsible for administering the federal food stamp program in Alabama, disqualified plaintiff Hessie Anderson’s and plaintiff Frankie Martin’s households from receiving food stamps on the basis of the Secretary’s voluntary quit regulation. The plaintiffs argue that the Secretary of the U.S. Department of Agriculture and the Commissioner of the Alabama Department of Pensions and Security violated the statutory provision on voluntary quit by disqualifying their households on the basis that their households’ primary wage earners quit their jobs; according to the plaintiffs, “head of household,” the term used by Congress, and “primary wage earner,” the term used by the Secretary, are not equivalent. Indeed, the plaintiffs argue that, at the time their households were disqualified, the heads of their households were different from their households’ primary wage earners. 4 For example, at the time Anderson’s household was disqualified, the primary wage earner in her household was her 18-year-old son. Her household consisted of twenty-five members, at least three of whom were employed shortly before this litigation began. Because the three incomes were not sufficient to support the entire household, the household received food stamps worth over $600.00 each month. Anderson’s husband was named on the food stamp application as the head of the household, but the Andersons’ 18-year-old son Lindsey was actually earning the most money. Lindsey quit his job in August 1985. After making an initial determination that Lindsey had not had good cause for quitting, the Alabama Department of Pensions and Security notified the Anderson household that the entire household would be disqualified from receiving food stamps for three months because Lindsey, the primary wage earner, had voluntarily quit his job without good cause.

II.

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644 F. Supp. 1372, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-lyng-almd-1986.