Daniels v. Woodbury County

742 F.2d 1128, 39 Fed. R. Serv. 2d 1346
CourtCourt of Appeals for the Eighth Circuit
DecidedSeptember 10, 1984
DocketNos. 83-2026, 83-2107
StatusPublished
Cited by23 cases

This text of 742 F.2d 1128 (Daniels v. Woodbury County) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniels v. Woodbury County, 742 F.2d 1128, 39 Fed. R. Serv. 2d 1346 (8th Cir. 1984).

Opinion

HENLEY, Senior Circuit Judge.

George Raymond Daniels and other applicants for general relief assistance in Woodbury County, Iowa brought suit under 42 U.S.C. § 1983 alleging, inter alia, that the administration of the general relief program violated the applicants’ procedural due process rights. The defendants are Woodbury County, the Woodbury County Board of Supervisors, and an individual caseworker and her supervisor. The district court1 granted the plaintiffs partial relief holding that defendants had violated the applicants’ due process rights. The court enjoined further due process violations and awarded three of the plaintiffs damages.

Plaintiffs contend that the district court’s injunction is not specific enough and seek a clearer enumeration of their due process rights. They also allege that the County’s lack of standards for determining whether applicants are qualified for relief violates due process and that the level of benefits provided by the County is inadequate. Finally, plaintiffs contend that the district court erred in not certifying the case as a class action.

The two individual defendants and the County have cross-appealed. Defendants contend that the court erred in awarding damages to three of the plaintiffs and that the current procedures used by the County provide applicants with all the process that is due. They assert that the standards of eligibility and level of benefits provided by the County comport with both the Constitution and Iowa law. We affirm in part and remand the case to the district court for further proceedings consistent with this opinion.

I. BACKGROUND

The General Relief Program

The general relief program involved here is a public assistance plan provided for by Iowa law and administered by the individual counties. See Iowa Code § 252 (1969). Woodbury County has enacted rules which set forth benefit levels, eligibility requirements, and program procedures.

These rules, as amended August 1, 1981, provide that upon application the applicant is entitled to a decision by the relief worker within twenty days. The worker must give the applicant an oral explanation of the decision with a written statement to be placed in the record. If the applicant is not present, a copy of the written statement is to be sent to the applicant. If the applicant receives less relief than requested, the rules provide that the applicant be informed, either orally or in writing, of the right to appeal to the County Board of Supervisors. If the applicant requests an appeal, the relief worker is to provide him or her with a copy of the appellate rules and “the reason for denial of the requested relief shall be stated to the applicant.” A de novo hearing is then held before the Board of Supervisors with the applicant given the opportunity to present evidence and cross-examine witnesses. If the applicant is not present at the time the Board renders its decision, a written statement of the decision is to be mailed to the applicant. Apparently a statement of reasons for the decision is not required.

An applicant is entitled to review his file but all “third party information” is kept from him. The applicant is required to “cooperate” with the worker and relief can be denied if the applicant does not do so.

The substantive rules of the County differentiate between “poor” and “needy” persons. A “poor” person is a person with no property and who is unable to earn a [1131]*1131living due to disability.2 A “needy” person is one who has “some property” and who has an immediate need for relief. Needy persons only qualify for relief on a temporary basis and must seek and obtain employment, usually with the County, as a precondition to eligibility. These restrictions apparently do not apply to poor persons.

Woodbury County employs two persons to operate the program. Georgia Schieffer is the fulltime general relief worker and makes most of the initial eligibility decisions. She is supervised by Ralph Klocke, the part-time general relief director. General relief is granted on a onetime basis for a specified period of time. The district court explained that “the concept of a ‘termination’ of benefits is not applicable to Woodbury County’s general relief program. To obtain relief beyond the period for which relief was previously granted, another application is required.” This relief program has been called a program of “last resort” wherein applicants are granted relief assistance for such items as food, clothing, shelter and medical expenses if the applicant shows immediate need for such assistance.

The District Court’s Decision

After a hearing the district court entered a preliminary injunction specifying certain temporary procedures to be followed by defendants.3 After several more days of trial, the court issued its final opinion. The court found that the actions of Schieffer and Klocke have resulted in arbitrary denials of benefits, in failures to notify claimants of their appeal rights, and in failures to provide claimants with the reasons for adverse decisions.4 The court found that the evidence showed that the administration of the relief program “has not always been in accordance with its own stated rules.”

In addition, the court found that three of the plaintiffs, George Daniels, Delores Farley and Bluette Caron, were deprived of their civil rights. The court found that, although none of the plaintiffs fit the definition of a “poor” person, some of them were incorrectly found not to be “needy,” and thus were arbitrarily denied benefits. The court stated that the two general relief workers had violated the due process rights of citizens by arbitrarily denying benefits to eligible applicants and that this was done in the name of saving money or conserving fiscal resources.5

Based on its findings, the court made the following conclusions of law: (1) the fourteenth amendment requires that due process be observed in acting upon applications for relief since the state statute and County rules created a property interest in the receipt of welfare benefits; (2) the general relief program, as administered by Woodbury County, violated due process; (3) the Board of Supervisors and the individual members of the Board did not act with a clear disregard for plaintiffs’ constitutional rights, and thus they were protected by good faith immunity; (4) Schieffer and Klocke should have known that their actions in arbitrarily denying benefits and in failing to give notice of appeal rights [1132]*1132were in violation of due process, and thus they were not protected by good faith immunity; (5) the County itself was also liable since the individual defendants acted pursuant to governmental custom; (6) the County was not protected by eleventh amendment immunity since the County received no state funds in operating the program; (7) the court determined that it had no authority to interfere with the actual benefit levels or eligibility standards; and (8) certification of a class action was not required.

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Bluebook (online)
742 F.2d 1128, 39 Fed. R. Serv. 2d 1346, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniels-v-woodbury-county-ca8-1984.