Genao v. State, 96-6276 (1997)

CourtSuperior Court of Rhode Island
DecidedMay 9, 1997
DocketC.A. No. 96-6276
StatusPublished

This text of Genao v. State, 96-6276 (1997) (Genao v. State, 96-6276 (1997)) is published on Counsel Stack Legal Research, covering Superior Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Genao v. State, 96-6276 (1997), (R.I. Ct. App. 1997).

Opinion

DECISION
The Department of Health of the State of Rhode Island entered an order disqualifying Reyes Market from participation in the Women, Infants, Children (WIC) Program. From that determination, petitioner filed a timely appeal pursuant to R.I.G.L. 1956 § 42-35-15.

Facts and Travel
This matter stems from an investigation of Reyes Market initiated by the Food and Nutrition Service of the United States Department of Agriculture. In a letter dated September 9, 1995, Mr. Genao was informed that an investigator from the USDA had observed him engaged in a transaction involving the purchase of food stamp coupons for cash. A subsequent letter from the USDA dated September 22, 1995 informed Mr. Genao that after a review of the available evidence, the department was of the opinion that Mr. Genao had in fact engaged in the purchase of food coupons for cash and that, as a result, he would be disqualified from participating in the Food Stamp Program. Mr. Genao appealed this determination to an Administrative Review Officer. This Officer upheld the USDA's original determination in a decision dated December 19, 1996. Mr. Genao appealed the suspension to the Rhode Island Superior Court. The matter was subsequently transferred to the Federal District Court for the District of Rhode Island. There, the parties entered into a Stipulation and Order of Settlement on March 26, 1996. Upon entry of this order, Mr. Genao's appeal was dismissed with prejudice and without costs upon certain conditions. These conditions included payment by Mr. Genao of a $20,000 fine and submission to a three year period of probation. In return, the USDA agreed to modify its decision to disqualify Reyes Food Market from participation in the Food Stamp Program.

During this period, the State of Rhode Island's WIC program was also in the process of sanctioning the petitioner. Specifically, on June 26, 1996, Mr. John Smith, Chief of the WIC Program, notified Mr. Genao that being subjected to a civil monetary penalty by the Food Stamp Program violates WIC program requirements and may be grounds for disqualification from the program. Moreover, the letter stated that in the event a fine is imposed, the term of disqualification from the WIC program will equal the term of disqualification from the Food Stamp Program. In a letter dated August 1, 1996, Mr. Genao was notified of the department's decision to disqualify Reyes Market until March 26, 1999, pursuant to the aforementioned letter of June 26, 1996, as a result of the Stipulation entered into by the parties in the United States District Court.

From this determination, the petitioner filed a request for an administrative review. This review commenced on September 12, 1996, but was continued until October 9, 1996, so that the petitioner could be served with proper notice of the charges pending against him and the specific basis for these charges.

At the hearing, testimony was offered by Mr. John Smith, Chief of the WIC Program. Specifically, Mr. Smith testified that because of the nature of the WIC program, WIC vendors must be more strictly monitored than those participating in the Food Stamp Program. According to Mr. Smith, such scrutiny is warranted because of the nature of a WIC reimbursement, which is, in effect, a blank check payable to the vendor.1 Therefore, only those vendors whose participation will benefit the program are considered for continued participation therein.

Mr. Smith also testified as to the criteria used to determine whether or not a disqualification was permissible in the instant matter. Specifically, Mr. Smith testified that under the rules and regulations of the program, WIC may disqualify a vendor only if it is established that such a disqualification will not pose a hardship to program participants. Mr. Smith then testified that he examined whether other WIC vendors in the vicinity of the Reyes Market stocked required WIC food items, whether these vendors charged prices comparable to Reyes, whether these vendors accept Food Stamps, and whether these vendors spoke Spanish. His testimony revealed that each of these inquiries was answered in the affirmative.

Mr. Smith testified that after weighing these factors, he determined that disqualifying Reyes would have no impact upon the WIC program because other markets in the area could provide for the WIC participant's needs. He also testified that in his opinion, in light of the totality of the circumstances, it was not in the best interest of the WIC program to continue to permit Reyes market to participate in the WIC program as a vendor because continued participation would in fact constitute a burden to the program.

Mr. Smith was cross examined by the petitioner as to exactly why he proposed to disqualify Reyes Market and the specific rules and regulations upon which he predicated his decision. In response, Mr. Smith cited the State Operations Manual, Section V-4, A.1 A.6 and Section V-1, B.2 B.3. Mr. Smith also testified that his determination was based in part on his belief that the Stipulation entered into in District Court represented a sanction of Reyes Market.

On November 4, 1996, the hearing officer issued his decision in which he denied the petitioner's appeal. The officer determined that Reyes Market should be disqualified from the WIC program for a period equal in length to the duration of its probation with the USDA Food Stamp Program and that Mr. Genao's WIC license should be surrendered to the Rhode Island Department of Health no later than November 8, 1996. From this decision, the petitioner filed the instant appeal on December 4, 1996.

Standard of Review
This review is controlled by R.I.G.L. 1956 § 42-35-15 (g), which provides that in the case of a review of a contested agency decision:

(g) The court shall not substitute its judgment for that of the agency as to the weight of the evidence on questions of fact. The court may affirm the decision of the agency or remand the case for further proceedings, or it may reverse or modify the decision if substantial rights of the appellant have been prejudiced because the administrative findings, inferences, conclusions, or decisions are:

(1) In violation of constitutional or statutory provisions;

(2) In excess of the statutory authority of the agency;

(3) Made upon unlawful procedure;

(4) Affected by other error or law;

(5) Clearly erroneous in view of the reliable, probative, and substantial evidence on the whole record; or

(6) Arbitrary or capricious or characterized by abuse of discretion or clearly unwarranted exercise of discretion.

R.I.G.L. 1956 § 42-35-15 (g).

This section precludes a reviewing court from substituting its judgment for that of the agency in regard to the credibility of witnesses or the weight of evidence concerning questions of fact. Costa v. Registry of Motor Vehicles, 543 A.2d 1307, 1309 (R.I. 1988); Carmody v. R.I. Conflict of Interest Commission,509 A.2d 453, 458 (R.I. 1986). Therefore, this Court's review is limited to determining whether substantial evidence exists to support the agency's decision.

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Related

Milardo v. Coastal Resources Management Council
434 A.2d 266 (Supreme Court of Rhode Island, 1981)
Newport Shipyard, Inc. v. Rhode Island Commission for Human Rights
484 A.2d 893 (Supreme Court of Rhode Island, 1984)
Berberian v. Department of Employment Security, Board of Review
414 A.2d 480 (Supreme Court of Rhode Island, 1980)
Caswell v. George Sherman Sand & Gravel Co.
424 A.2d 646 (Supreme Court of Rhode Island, 1981)
Carmody v. Rhode Island Conflict of Interest Commission
509 A.2d 453 (Supreme Court of Rhode Island, 1986)
Costa v. Registrar of Motor Vehicles
543 A.2d 1307 (Supreme Court of Rhode Island, 1988)

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Bluebook (online)
Genao v. State, 96-6276 (1997), Counsel Stack Legal Research, https://law.counselstack.com/opinion/genao-v-state-96-6276-1997-risuperct-1997.