Coakley v. Sunn

895 F.2d 604, 1990 WL 7478
CourtCourt of Appeals for the Ninth Circuit
DecidedFebruary 5, 1990
DocketNo. 88-1676
StatusPublished
Cited by11 cases

This text of 895 F.2d 604 (Coakley v. Sunn) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coakley v. Sunn, 895 F.2d 604, 1990 WL 7478 (9th Cir. 1990).

Opinion

O’SCANNLAIN, Circuit Judge:

Recipients of food stamps and aid to families with dependent children (“AFDC”) challenge a State of Hawaii interpretation of the federal so-called “lump sum” rule which provides that AFDC recipients whose income temporarily exceeds a certain level become ineligible to receive benefits for a fixed period of time.

[605]*605I

Rillo, an AFDC recipient, was awarded $18,500 in the settlement of a personal injury claim, of which she received more than $11,000. The Hawaii Department of Social Services and Housing (“DSSH”), which administers AFDC for the state, categorizes such personal injury damage awards as “income” under the federal lump sum rule.1 42 U.S.C. § 602(a)(17)(Supp. Y 1987). The rule provides that an AFDC recipient who receives a lump sum of income becomes ineligible for benefits for as many months as the income would last if the recipient were to spend an amount equal to the state’s standard of need each month. Id. Therefore, Hawaii disqualified Rillo and her family from receiving AFDC benefits for 21 months, a period it calculated by dividing Rillo’s damages award by her monthly AFDC assistance payment of $468.00. Rillo placed her personal injury award into a bank account.

Rillo also had been receiving some $281.00 a month of food stamps prior to her personal injury settlement. As a result of her depositing the award, however, Ril-lo’s bank balance exceeded the food stamp eligibility resource level of $2000;2 therefore, DSSH terminated her benefits under that program as well. Because she had lost her food stamp eligibility, Rillo had to spend some of her lump sum to purchase food. Consequently, Rillo depleted the lump sum prior to the conclusion of her lump sum ineligibility period.3

In October 1985, Rillo (and Coakley) filed this class action suit in the district court against DSSH Director Sunn (“the Director”) based on federal question jurisdiction. 28 U.S.C. § 1331 (1982). The original complaint contains three claims: (1) that the Director’s policy of treating personal injury awards as “income” under AFDC violates certain provisions of the Social Security Act (“the Act”), 42 U.S.C. §§ 602(a)(7), 602(a)(10) and 602(a)(17) (Supp. V 1987); (2) that this same policy violates the equal protection clause of the fourteenth amendment; and (3) that the Director’s failure to notify appellants of the policy’s impact on AFDC eligibility prior to their receiving personal injury awards was improper. In turn, the Director filed a third party complaint against the U.S. Secretary of Health and Human Services (“the Secretary”). The district court certified a class action, but granted summary judgment upholding the validity of the Director’s actions as to the first two of appellants’ claims, leaving the third claim relating to “notice” undecided (“the notice claim”). The court also denied the plaintiffs’ motion for a preliminary injunction. None of these court rulings is before us.

Appellants then filed an amended complaint alleging a fourth claim (“the unavailability claim”) that the Director has “unduly limited the scope” of the so-called “unavailability rule,” a federal statutory provision which permits states to recalculate an AFDC recipient's period of ineligibility if the recipient’s lump sum. income becomes “unavailable.” The unavailability rule provides that “the State may at its option recalculate the period of ineligibility ... [if] the income received has become unavailable to the members of the family for reasons that were beyond the control of such members ...” 42 U.S.C. § 602(a)(17).4

Currently, DSSH shortens an AFDC recipient’s ineligibility period under the lump sum rule when, among other things, the [606]*606income becomes unavailable either because of loss or theft or because the individual with control over the income leaves the home. Haw.Admin. Rule § 17-621-46(e)(l) (1984).5 Appellants claim that Hawaii’s failure to include them within its “unavailability rule” violates federal law because a portion of their lump sum income has become “unavailable” due to circumstances beyond their control for other reasons. Appellants asked the court in their fourth claim to declare the Director’s interpretation of the “unavailability rule” unconstitutional under the due process clause of the fourteenth amendment as well as violative of the federal statute and regulation whence it derived. The Director did not assert a third party claim against the Secretary as to this fourth claim.

The district court eventually dismissed the “notice” claims with prejudice, certified a class with respect to the unavailability claims,6 and then dismissed the unavailability claims, again upholding the validity of the Director’s action. Appellants timely appeal the adverse judgment on their “unavailability” claim.

II

Article III of the United States Constitution limits our jurisdiction to actions involving actual “eases” or “controversies,” a limitation that manifests itself through the doctrine of standing. Secretary of State v. Joseph H. Munson Co., 467 U.S. 947, 954, 104 S.Ct. 2839, 2845, 81 L.Ed.2d 786 (1984); Ripplinger v. Collins, 868 F.2d 1043, 1047 (9th Cir.1989). In order to establish standing to pursue a claim under Article III,7 a plaintiff must allege personal injury that is fairly traceable to defendant’s allegedly unlawful conduct and that the requested relief is likely to redress. Allen v. Wright, 468 U.S. 737, 751, 104 S.Ct. 3315, 3324, 82 L.Ed.2d 556 (1984) (citing Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., 454 U.S. 464, 472, 102 S.Ct. 752, 758, 70 L.Ed.2d 700 (1982)); Ripplinger, 868 F.2d at 1047. That is, the litigant must allege a distinct and palpable injury to himself; that the injury is somehow directly linked to the challenged activity; and that the injury is one which is apt to be redressed by a remedy the court is prepared to give. See Allen, 468 U.S. at 751, 104 S.Ct. at 3324; see also Wright, Miller, & Cooper, 13 Federal Practice and Procedure, § 3531.4, at 418.

Appellants clearly satisfy the first two elements of the Article III standing inquiry with respect to their unavailability claim. First, they have adequately alleged injury through the loss of their AFDC benefits for the full duration of the lump sum ineligibility period.

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Bluebook (online)
895 F.2d 604, 1990 WL 7478, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coakley-v-sunn-ca9-1990.