Kenyon v. Sullivan

761 F. Supp. 951, 1991 U.S. Dist. LEXIS 5121, 1991 WL 58812
CourtDistrict Court, D. Rhode Island
DecidedApril 10, 1991
DocketCiv. A. 89-0553P
StatusPublished
Cited by9 cases

This text of 761 F. Supp. 951 (Kenyon v. Sullivan) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kenyon v. Sullivan, 761 F. Supp. 951, 1991 U.S. Dist. LEXIS 5121, 1991 WL 58812 (D.R.I. 1991).

Opinion

MEMORANDUM AND ORDER

PETTINE, Senior District Judge.

Plaintiffs are a class, certified by order of January 24, 1990, consisting of:

All past, present and future [Aid to Families with Dependent Children (“AFDC”) ] recipients whose right to receive child support has been assigned to the Rhode Island Department of Human Services and (a) on whose behalf child support has been or will be paid to DHS or to its counterpart in another state since October 1, 1984 and (b) who have not received the $50 payments they should have received pursuant to federal law.

On October 4, 1989, plaintiffs filed this action against Anthony Barile, then Director of the Rhode Island Department of Health and Human Services (“DHS”) (Dawn Sullivan, the current director, has since been substituted as defendant under Fed.R.Civ.P. 25), challenging the state’s method of distributing “pass-through” payments from child support received by the state on behalf of the plaintiffs.

Plaintiffs bring this action under 42 U.S.C. § 1983, asserting four basic claims: (1) that since October 1984 DHS has failed to properly pass through the first $50 of child support collected, in violation of plaintiffs’ rights under 42 U.S.C. §§ 602(a)(24) and 657(b)(1); (2) that DHS’ failure to pass through the first $50, without notice of the amount of support collected and the determination that there would be no pass-through, and the failure to provide an opportunity for a hearing on the determination, deprives plaintiffs of property without due process of law in violation of the Fifth and Fourteenth Amendments; (3) that defendant’s failure to make pass-through payments deprives the plaintiffs of property in violation of their substantive due process rights under the Fifth and Fourteenth Amendments; and (4) that defendant’s pre-January 1989 policy and practice of making pass-through payments only where the support is both paid and received by DHS in the month when due, yet withholding pass-through payments from recipients where DHS failed to receive support in a month when due, whether or not the absent parent made a timely payment, treats similarly situated groups of AFDC recipients differently without a rational basis and thus violates plaintiffs’ rights under the equal protection clause of the Fourteenth Amendment. Plaintiffs seek declaratory and in-junctive relief.

*954 DHS filed a third party complaint against Louis Sullivan, Secretary of the United States Department of Health and Human Services (“HHS”), seeking to bind the federal government to any decision of this Court due to the joint responsibilities of the state and federal agencies in carrying out the AFDC program.

Plaintiffs first filed a motion on April 20, 1990 seeking summary judgment only on their pre-1989 statutory claims. Later, on October 11, 1990, plaintiffs filed a subsequent motion for summary judgment which incorporated their earlier motion for partial summary judgment and also sought summary judgment on their statutory claims for the period after January 1989 and on all constitutional claims; this most recent motion thus seeks final judgment on all claims brought by plaintiffs. Also pending is third-party defendant’s motion to dismiss the third-party complaint, which I deny.

It is well-settled that a motion for summary judgment under Fed.R.Civ.P. 56 will be granted only if a court finds that there is “no genuine issue of material fact.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 2510, 91 L.Ed.2d 202 (1986). “[SJubstantive law will identify which facts are material.... [and] summary judgment will not lie if the dispute ... is genuine, that is, if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Id. A court must construe all factual inferences in the non-moving party’s favor. Voccio v. General Signal Corp., 732 F.Supp. 292, 294 (D.R.I.1990). As set out below, I find that the material facts are not in dispute and that plaintiffs have demonstrated that they are entitled to judgment as a matter of law; summary judgment is, therefore, granted in their favor.

I. Statutory and Factual Background

A. Federal Statutory Scheme

Rhode Island participates in AFDC, a federal spending program to aid low-income families authorized by Subchapter IV-A of the Social Security Act, 42 U.S.C. §§ 601-15. The federal government provides matching funds equal to 50% of a state’s expenditures carried out under a plan approved by the Social Security Administration. 42 U.S.C. §§ 1301(a)(8), 1396d(b).

As a prerequisite to receiving AFDC benefits, a parent is required to assign to the state his or her right to child support payments. 42 U.S.C. § 602(a)(26) (1990). The Child Support Enforcement Program, Title IV-D of the Social Security Act, sets out the method of distributing the support payments collected by the state. Id. § 657. The Deficit Reduction Act of 1984 (“DEFRA”), effective October 1, 1984, allowed the first $50 of support collected to be passed through to the AFDC recipient. Until January 1, 1989, when it was amended by the Family Support Act of 1988 (Pub.L. 100-485, § 102), section 657(b)(1) provided that:

The first $50 of such amounts as are collected periodically which represent monthly support payments shall be paid to the family without affecting its eligibility for assistance or decreasing any amount otherwise payable as assistance to such family during such month. Id. § 657(b)(1) (1982 Supp. IV), amended by 42 U.S.C. § 657(b)(1) (1990).

Section 602(a)(8)(A)(vi) required the agency to disregard the first $50 when determining the families’ eligibility for AFDC benefits. Id. § 602(a)(8)(A)(vi) (1982 Supp. IV), amended by 42 U.S.C. § 602(a)(8)(A)(vi) (1990). Pursuant to the statute, the Secretary of HHS promulgated 45 C.F.R. § 302.51(b)(1), interpreting section 657(b)(1) as allowing only one $50 payment per month, and then only if the support payment was received by the recipient's state in the month when due. 1

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Bluebook (online)
761 F. Supp. 951, 1991 U.S. Dist. LEXIS 5121, 1991 WL 58812, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenyon-v-sullivan-rid-1991.