Jackson v. Va. Department of Social Services

10 Va. Cir. 294, 1987 Va. Cir. LEXIS 110
CourtRichmond County Circuit Court
DecidedDecember 7, 1987
DocketCase No. C-9512-1; Case No. N-2608-3; Case No. N-2459-1
StatusPublished

This text of 10 Va. Cir. 294 (Jackson v. Va. Department of Social Services) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jackson v. Va. Department of Social Services, 10 Va. Cir. 294, 1987 Va. Cir. LEXIS 110 (Va. Super. Ct. 1987).

Opinion

By JUDGE MELVIN R. HUGHES, JR.

Because of the similarity of the issues involved in these three cases, the Court has decided to consolidate them for purposes of this opinion. Jackson v. Virginia Department of Social Services et al., Case No. C-9512 (Jackson), and Turner v. Lukhard, Case No; N-2608-3 (Turner), are pending on demurrer. Latney v. Jackson, Case No. N-2459-1 (Latney), is pending on defendant’s Motion for Summary Judgment. For reasons stated herein, defendants’ demurrer in Latney is reconsidered.

All the cases involve one or more welfare (Aid to Dependent Children) recipients aggrieved by a decision of the Department of Social Services to reduce or terminate their benefits. The plaintiffs in these cases have then brought suits in equity challenging the agency regulation or policy underlying the reduction in benefits and seeking (1) a declaration that the agency regulation is or was unlawful and (2) an injunction requiring the agency to provide the plaintiffs with retroactive benefits. In Jackson and Turner, the named plaintiffs seek to represent all ADC applicants and recipients similarly affected by the regulation at issue and seek class-wide relief.

Considering only the merits of the plaintiffs’ claims, the claims are substantial. In Turner, the plaintiffs seek the same relief (retroactive benefits) that the court awarded to similarly situated plaintiffs in the case of Brown v. Lukhard, 229 Va. 316 (1985). The Brown court held that benefits for students aged 18-21 were unlawfully reduced for a three-month period in 1981. In Latney, the plaintiff seeks a ruling that the present ADC standards of need, used to determine eligibility for assistance, do not provide a reasonable subsistence. The Virginia Code requires that assistance payments provide a reasonable subsistence. Federal regulations require that States set standards of need and that assistance payments be less than or equal to the standards of need. 45 C.F.R. § 233.20(a)(2)(i), (ii). Agency officials have made formal statements before other government officials that the present standards are too low. The Jackson plaintiffs claim that the agency erred in interpreting a federal regulation as requiring that receipts from sales by ADC recipients of their "resources" become "income" rather [296]*296than remaining a resource. Official comments in the Federal Register explaining the federal regulation appear to indicate that the plaintiffs are correct on this matter, contrary to the agency’s assertion that it acted in accordance with federal policy.

Jurisdiction

However, before addressing the merits of these claims, the Court must consider whether it has the jurisdiction to do so. The Virginia Constitution, art. VI, § 1, provides that the "General Assembly shall have the power to determine the original and appellate jurisdiction of the courts of the Commonwealth." The General Assembly has established an administrative appeal process for "[a]ny applicant or recipient aggrieved by any decision of a local board in granting, denying, changing or discontinuing assistance." Va. Code § 63.1-116. The plaintiffs in all of the cases clearly are subject to this appeal process. The aggrieved person must appeal to the State Board of Social Services within thirty days after receiving notice of the local board’s decision. § 63.1-116. The State Board must provide an opportunity for a hearing and give fair and impartial consideration of the testimony of witnesses or other evidence produced at the hearing. § 63.1-117. The State Board may delegate its authority to make a determination on an appeal to a duly organized hearing officer, whose decision may be reviewed by the State Board upon the request of the applicant/recipient or the local board. Section 63.1-116. The State Board’s decision shall be final and not subject to further review except by the State Board itself. § 63.1-119.

The legislature has expressed its intent to make this administrative remedy exclusive in § 63.1-119. For this reason, the Court considers itself without jurisdiction to entertain the Latney case. Upon suspension of her ADC benefits, Mrs. Latney could have appealed the local board’s decision to the State Board within the prescribed time period for a hearing. She failed to appeal, according to counsel at oral argument. She is therefore estopped from contesting her case decision and the underlying regulation in court.

[297]*297In the Jackson case, Ms. Jackson did seek and obtain a hearing at the State Board level on her claim. She was dissatisfied with the Board’s decision because the Board did not admit to having made a mistake in construing federal policy and therefore did not provide her with retroactive relief, although it did provide prospective relief. Because of the finality of the Board’s decision on appeal, the Court is without jurisdiction to hear Ms. Jackson’s claim. Although Ms. jackson filed a second administrative appeal specifically protesting the lack of retroactive relief and the Board dismissed the appeal without a hearing, the issue on appeal can fairly be said to have been decided in the prior Board decision.

Ms. Jackson also protests an alleged failure of the agency to (1) meaningfully inform the class of plaintiffs of the policy change in 1981 reducing the plaintiffs’ assistance, (2) notify the plaintiffs of their right to a hearing to contest the agency’s decision not to provide retroactive benefits, and (3) provide for reinstatement of benefits to the plaintiffs rather than for reapplication for benefits after the agency’s decision on Ms. Jackson’s appeal, in violation of federal and state regulations. Ms. Jackson, however, does not show now she herself was harmed by these alleged wrongs. She was aware of her administrative appeal rights, asserted them, and is bound by the Board’s decision regarding her rights.

The named plaintiff in Turner, however, present a materially different case. Affidavits by plaintiffs Turner and Riley indicate that at least some of the named plaintiffs tried to appeal but were denied a hearing by the Board. The denials were based on a regulation disallowing hearings when state or federal law requires automatic grant adjustments for classes of recipients. Since these plaintiffs were never afforded an opportunity for a hearing, the State Board never made a final decision on the merits and the finality provision of § 63.1-119 cannot be held to apply. The claims of Ms. Turner and Ms. Riley have already been satisfied by the agency and the suit is thus moot for them, but not for the other similarly situated named plaintiffs. The apparent futility of their trying to obtain an administrative hearing on this issue prevents the estoppel of these plaintiffs from bringing their claims to court.

[298]*298 Sovereign Immunity

The question of the jurisdictional basis for the Turner plaintiffs’ claims still remains, though. The Commissioner of Social Services, William L. Lukhard (a defendant in each case), has pleaded sovereign immunity in each case. On this plea, the critical question appears to be whether the suit is, in effect, against the state, or against an officer to restrain him from acting outside of his authority. This distinction is critical in the case of Larson v. Domestic and Foreign Commerce Corp.,

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Bluebook (online)
10 Va. Cir. 294, 1987 Va. Cir. LEXIS 110, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-va-department-of-social-services-vaccrichmondcty-1987.