K.S. v. Department of Human Services

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 23, 2026
DocketA-0877-24
StatusUnpublished

This text of K.S. v. Department of Human Services (K.S. v. Department of Human Services) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
K.S. v. Department of Human Services, (N.J. Ct. App. 2026).

Opinion

RECORD IMPOUNDED

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0877-24

K.S.,1

Petitioner-Appellant,

v.

DEPARTMENT OF HUMAN SERVICES, DIVISION OF FAMILY DEVELOPMENT,2 and UNION COUNTY DIVISION OF SOCIAL SERVICES,

Respondents-Respondents. ____________________________

Submitted December 18, 2025 ‒ Decided March 23, 2026

Before Judges Bishop-Thompson and Puglisi.

On appeal from the New Jersey Department of Human Services, Division of Family Development, Docket No. C402092020.

K.S., self-represented appellant.

1 We use initials to protect the petitioner's privacy interests. 2 The caption omits the Department of Human Services, Division of Family Development, which we have corrected in our opinion. Matthew J. Platkin, Attorney General, attorney for respondent Department of Human Services, Division of Family Development (Donna Arons, Assistant Attorney General, of counsel; Elizabeth M. Tingley, Deputy Attorney General, on the brief).

PER CURIAM

Petitioner K.S. appeals from the August 29, 2024 final agency decision

issued by the Department of Human Services, Division of Family Development

(DFD). The DFD's decision, which followed a hearing before an Administrative

Law judge (ALJ), terminated K.S.'s emergency assistance (EA) benefits and

imposed a six-month ineligibility period for those benefits.. We affirm.

On appeal, K.S. contends the ALJ erred in terminating her EA benefits for

housing. She argues there was sufficient evidence in the record showing she

was not approved for Section 8 housing3 and, as a result, her emergency hardship

stay for rental assistance and homeless shelter placement should not have been

for six months.

3 The Section 8 Housing Voucher Program is funded by the U.S. Department of Housing and Urban Development and assists in making safe and quality housing in the private rental market affordable to low- and very low-income households by reducing housing costs through direct rent subsidy payments to landlords. Section 8 Housing Choice Voucher, Dep't of Cmty. Affs., https://www.nj.gov/dca/dhcr/offices/section8hcv.shtml (last visited March 9, 2026). The program is administered through the New Jersey Department of Community Affairs (DCA). A-0877-24 2 The DFD argues however, the matter is moot. It asserts, following the

period of disqualification, K.S. reapplied for and was subsequently found

eligible for EA benefits.

"An issue is 'moot when our decision sought in a matter, when rendered,

can have no practical effect on the existing controversy.'" Redd v. Bowman,

223 N.J. 87, 104 (2015) (quoting Deutsche Bank Nat'l Tr. Co. v. Mitchell, 422

N.J. Super. 214, 221-22 (App. Div. 2011)). Moreover, an issue is also moot

when the controversy no longer exists, and the issue presented has been

resolved. See Caput Mortuum LLC v. S & S Crown Servs. Ltd., 366 N.J. Super.

323, 330 (App. Div. 2004) (citing Advance Elec. Co. v. Montgomery Twp. Bd.

of Educ., 351 N.J. Super. 160, 166 (App. Div. 2002) (stating "[o]ur courts

generally will not decide a case if . . . a judgment cannot grant effective relief")).

The dispute between the parties concerning K.S.'s six-month

disqualification period for EA benefits has been resolved. Therefore, we see no

reason to address this aspect of K.S.'s argument raised on appeal.

Separate from her challenge regarding the six-month disqualification

penalty, K.S. also contests the termination of her EA benefits. A court's review

of an agency's determinations is limited. Allstars Auto Grp., Inc. v. N.J. Motor

Vehicle Comm'n, 234 N.J. 150, 157 (2018) (citing Russo v. Bd. of Trs., Police

A-0877-24 3 & Firemen's Ret. Sys., 206 N.J. 14, 27 (2011)). "We review a decision made by

an administrative agency entrusted to apply and enforce a statutory scheme

under an enhanced deferential standard." E. Bay Drywall, LLC v. Dep't of Lab.

& Workforce Dev., 251 N.J. 477, 493 (2022) (citing Hargrove v. Sleepy's, LLC,

220 N.J. 289, 201-02 (2015)).

We "review[] agency decisions under an arbitrary and capricious

standard." Zimmerman v. Sussex Cnty. Educ. Servs. Comm'n, 237 N.J. 465,

475 (2019) (citing In re Stallworth, 208 N.J. 182, 194 (2011)). Therefore, an

agency determination on the merits "will be sustained unless there is a clear

showing that it is arbitrary, capricious, or unreasonable, or that it lacks fair

support in the record." Saccone v. Bd. of Trs., Police & Firemen's Ret. Sys.,

219 N.J. 369, 380 (2014) (quoting Russo, 206 N.J. at 27).

EA benefits in the form of emergency shelter and housing assistance are

administered at the county level consistent with DFD's supervision and relevant

regulations. See N.J.A.C. 10:90-6.3(a). "[EA] shall be made available through

the Work First New Jersey [(WFNJ)] program as a supportive service to meet

the emergent needs of WFNJ recipients, so that recipients shall not be prevented

from complying with the work requirement due to disruptions caused by

homelessness and related emergencies." N.J.A.C. 10:90-6.1(a). In essence, the

A-0877-24 4 program functions as a social safety net, offering safe and affordable housing to

individuals experiencing significant hardship.

As a Supplemental Security Income benefits recipient, K.S. is eligible for

EA due to a physical disability. She applied for Section 8 housing through the

Union County Division of Social Services (UCDSS). On August 7, 2023, she

acknowledged and signed for receipt of a Housing Choice Voucher (HCV),

which had an expiration date of October 6, 2023, with an extension of expiration

until February 5, 2024.

K.S. received and signed a revised September 20, 2023 EA Service Plan

for temporary housing at a hotel in East Orange. The plan, which began on that

date and continued through February 20, 2024, outlined the program's benefits

and requirements. Under the section entitled Client's Service

Plan/Responsibilities, the box checked for Other, states: "YOU ARE

APPROVED FOR SECTION 8 VOUCHER EFFECTIVE [August 7, 2023] –

[October 6, 2023]. IF YOU FAIL TO FIND AN APARTMENT AND [LOSE]

YOUR SECTION 8 VOUCHER THE AGENCY WILL IMPOSE A SIX-

MONTH PENALTY. YOU WILL NOT RECEIVE ANY FORM OF

EMERGENCY ASSISTANCE FOR SIX-MONTHS." K.S. also signed a WFNJ

A-0877-24 5 Individual Responsibility Plan, which contained this same language regarding

the consequences of non-compliance.

K.S. did not obtain housing by the extended expiration date. As a result,

UCDSS terminated her EA benefits effective March 31, 2024, and imposed a

six-month penalty beginning April 1, 2024.

K.S. appealed the March 31 termination, which was stayed pending the

hearing. At the fair hearing, the ALJ addressed the UCDSS's determination.

The judge considered documentary evidence and the testimony of K.S. and a

DCA supervising field representative.

The ALJ issued an initial decision on July 26, 2024, determining K.S. had

not established good cause for her refusal to accept and secure a Section 8

apartment during the 180-day HCV period, as her primary reason was a

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