Quattlebaum v. Barry

671 A.2d 881, 1995 D.C. App. LEXIS 256, 1995 WL 755080
District of Columbia Court of Appeals·Decided December 21, 1995·No. 92-CV-504·Published·Cited by 4 cases

Opinions

ON REHEARING EN BANC

PER CURIAM: **

In 1991, the Council of the District of Columbia, confronted with a serious revenue shortfall, enacted legislation, subsequently signed by the Mayor, which reduced the benefit entitlements of AFDC recipients1 to October 1, 1989 levels and eliminated the annual COLA2 which recipients had previously received. See Budget Conformity Amendment Act of 1991, D.C. Law 9-27 (August 17, 1991). Appellants, AFDC recipients who were adversely affected by these benefit reductions, brought a class action in the Superior Court against the Mayor and other District officials (collectively the District), seeking injunctive and other relief. Appellants contended that the Council had unlawfully reduced their benefits, in violation of 7 U.S.C. § 2017(b) (1988), by improperly taking into consideration AFDC recipients’ entitlement to receive food stamps. They also claimed that the Council had failed to reassess the current minimum needs of AFDC recipients, in violation of D.C.Code § 3-205.44.3 Finally, appellants asserted that the individual notices advising AFDC recipients of the reductions were not in compliance with statutory and constitutional requirements.

Parties filed cross-motions for summary judgment and, on April 13, 1993, the trial judge issued a comprehensive opinion in which he granted the District’s motion. Quattlebaum v. Dixon, 120 Daily Wash. L.Rptr. 1925 (Super.Ct.D.C.1992) (Quattlebaum I). The AFDC recipients appealed and, on October 20, 1994, in Quattlebaum II, supra note 1, a division of this court reversed the judgment, holding that the Council had improperly considered the AFDC recipients’ entitlement to food stamps and that the notices to the recipients were insufficient.4 On [883] March 27, 1995, this court, sitting en banc, vacated the division opinion and granted the District’s petition for rehearing en banc. We now affirm the trial court’s principal rulings and sustain the validity of the benefit reductions.5

I.

THE FOOD STAMP ACT CLAIM

A The Facts.

The facts of record are largely undisputed. They are described in detail both in the trial judge’s memorandum opinion, Quattlebaum I, 120 Daily Wash.L.Rptr. at 1928-31, and in the opinion of the division. Quattlebaum II, 648 A.2d at 952-54. We recite only those facts, and address only those issues, which we view as necessary to decide this appeal.

In March 1991, during a fiscal crisis which has not abated in the interim, former Mayor Sharon Pratt Kelly presented to the Council her budget proposal for Fiscal Years 1991 and 1992. She recommended that the Council suspend the previously automatic annual COLA for AFDC recipients, and that individual entitlements be rolled back by 4.5% to 1989 levels.

On April 25,1991, the Council’s Committee on Human Services issued a Report6 recommending that the Mayor’s budget proposals be adopted. The Committee reported that “funding simply does not exist to fund adequately each and every program which the District has provided for in the past.” 7

Under federal law, the value of food stamp allotments which state agencies are authorized to issue increases as an eligible recipient’s income decreases. See 7 U.S.C. § 2017(a) (1991). Recognizing that the law operates in this manner, the Committee noted that the loss of AFDC benefits would be partially offset by an increase in the food stamp allotment for which some affected recipients would be eligible. Report, at 6. The Report contained the following table:

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Id. The Report further described a meeting of the Committee at which

Councilmember [Wilhelmina] Rolark noted that these types of reductions were devastating, because they “hit the most vulnerable of our population, the poor.” She further noted that she understood that we are [884] in a budget crisis, and inquired as to whether this bill was one of those budget conformity pieces of legislation. Chairman [H.R.] Crawford responded in the affirmative. Mr. Crawford further indicated that this bill was requested by the Executive and that some of the difference in the public assistance reductions would be offset in the allocation of [flood [s]tamps.... Mr. Crawford further reminded the Committee that he had to work within the funds that “were allocated to the human services budget, that we did not allow the workers of the District of Columbia a COLA, or pay an increase in the last 2 years.” He noted that everyone must participate in the terrible budgetary crisis we are facing in the District. Couneilmember Rolark indicated that she understood and commended the chairman for having worked hard to off-set the reductions.

Id. at 17 (emphasis added).

B. The Trial Judge’s Decision.

The provision of the Food Stamp Act on which appellants rely states that

[t]he value of the allotment provided any eligible household shall not be considered income or resources for any purpose under any Federal, State, or local laws, including ... welfare, and public assistance programs, and no participating State or political subdivision thereof shall decrease any assistance otherwise provided an individual or individuals because of the receipt of an allotment under this chapter.

7 U.S.C. § 2017(b) (1988) (emphasis added). Appellants claimed at trial, and now contend in this court, that the references to food stamp eligibility in the Committee’s Report demonstrated that AFDC benefits were rolled back “because of’ recipients’ eligibility for food stamps, in violation of § 2017(b).

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Quattlebaum v. Barry, 671 A.2d 881, 1995 D.C. App. LEXIS 256, 1995 WL 755080 (D.C. 1995).

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