Murray v. Lyng

667 F. Supp. 668
CourtDistrict Court, D. Minnesota
DecidedMay 19, 1987
DocketCivil 4-85-611
StatusPublished
Cited by5 cases

This text of 667 F. Supp. 668 (Murray v. Lyng) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murray v. Lyng, 667 F. Supp. 668 (mnd 1987).

Opinion

MEMORANDUM OPINION AND ORDER

DIANA E. MURPHY, District Judge.

Plaintiffs Debra Murray and Annadine Houle brought this action on behalf of themselves and a class of Minnesota foster parents and food stamp recipients against defendant Richard E. Lyng, as Secretary of the United States Department of Agriculture (the “Secretary”), and defendant Leonard Levine, as Commissioner of the Minnesota Department of Human Services. 2 Plaintiffs challenge regulations of the United States Department of Agriculture that require foster children to be included in their food stamp “households” and foster care maintenance payments to be included as unearned income in their food stamp “income.” 7 C.F.R. §§ 273.1, 273.9(b)(2)(ii). These regulations allegedly reduce plaintiffs’ food stamp allotments. Plaintiffs’ first three causes of action allege that the household and income regulations are not reasonable constructions of provisions of the Food Stamp Act. 7 U.S.C. §§ 2014(d)(6), (5), and (9). Plaintiffs’ fourth cause of action alleges that the regulations violate their right to due process by creating an irrebutable presumption that the amount of foster care payments exceeds the cost of providing that care. Finally, plaintiffs allege that the regulations violate their right to equal protection by providing foster child households with fewer food stamps than otherwise similar households not providing foster child care.

Plaintiffs seek a declaratory judgment that the regulations violate the Food Stamp Act and the Constitution, injunctive relief prohibiting defendants from continuing to enforce the regulations, and injunctive relief requiring defendants to restore to plaintiffs the food stamps they would have received since April 1984 absent the regulations. Jurisdiction is alleged pursuant to 28 U.S.C. §§ 1331, 1337 and 1343.

*670 The court has previously denied the Secretary’s motion to dismiss and granted plaintiffs’ uncontested motion for class certification. Now before the court are cross motions for summary judgment. 3 Background

Plaintiffs Debra Murray and Annadine Houle are licensed foster parents who provide care for foster children placed in their homes by the Hennepin County Bureau of Social Services. 4 They each receive monthly foster care maintenance payments to cover the costs of providing for their respective foster children. In addition, they each receive, or have received, food stamp allotments. They allege that these allotments would have been greater had the Secretary’s regulations not included the foster children in their food stamp “households” and the foster care maintenance payments in their income. 5 Plaintiffs Murray and Houle are the named representatives of a class defined as “all persons in Minnesota whose Food Stamp benefits have been reduced, terminated or denied from May 1, 1984 onwards as a result of their receipt of foster care maintenance payments'.”

A. The Food Stamp Act

In passing the Food Stamp Act, 7 U.S.C. §§ 2011-2029, Congress sought to “safeguard the health and well-being of the Nation’s population by raising levels of nutrition among low-income households.” 7 U.S.C. § 2011. Under the Act, the states administer the food stamp program in accordance with federal statutes and regulations. 7 U.S.C. § 2020. The federal government provides the entire funding for the cost of the benefits and for at least 50 percent of each state’s administrative costs. 7 U.S.C. §§ 2013, 2025.

Food stamps are distributed on a household basis. The Act defines a “household” as:

(1) an individual who lives alone or who, while living with others, customarily purchases food and prepares meals for home consumption separate and apart from the others, or (2) a group of individuals who live together and customarily purchase food and prepare meals together for home consumption; except that parents and children, or siblings, who live together shall be treated as a group of individuals who customarily purchase and prepare meals together for home consumption even if they do not do so, unless one of the parents, or siblings, is an elderly or disabled member.

7 U.S.C. § 2012(i). The Minnesota Department of Human Services Food Stamp Manual utilizes a similar definition. § III-C.

In 1978, the Secretary promulgated a regulation under the statute which provided that “[i]n no event shall nonhousehold member status ... be granted to [cjhildren under 18 years of age under the parental control of an adult member of the household.” 7 C.F.R. § 273.1(a)(3)(h) [the “household” regulation]. This regulation was recently amended to provide that “[c]hildren under 18 years of age under the parental control of an adult household member [living with others] shall be con *671 sidered as customarily purchasing food and preparing meals together, even if they do not do so.” 7 C.F.R. § 273.1(a)(2)(i)(B). The Secretary interprets the regulation to require the inclusion of foster children in the foster parent’s food stamp household.

The Food Stamp Act defines “[hjousehold income for purposes of the food stamp program” as:

all income from whatever source excluding only ... (5) reimbursements which do not exceed expenses actually incurred and which do not represent a gain or benefit to the household ... (6) moneys received and used for the care and maintenance of a third-party beneficiary who is not a household member ... (9) the cost of producing self-employed income____

7 U.S.C. § 2014(d). These three exclusions from household income form the basis for plaintiffs’ first three causes of action. The Secretary has promulgated a regulation under this statute which includes “foster care payments for children or adults” as unearned income. 7 C.F.R. § 273

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Related

Murray v. Lyng
854 F.2d 303 (Eighth Circuit, 1988)
Rios v. South Dakota Department of Social Services
420 N.W.2d 757 (South Dakota Supreme Court, 1988)
Foster v. Celani
683 F. Supp. 84 (D. Vermont, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
667 F. Supp. 668, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murray-v-lyng-mnd-1987.