The National Welfare Rights Organization v. The Honorable Robert Finch, Secretary, United States Department of Health, Education and Welfare National Welfare Rights Organization v. The Honorable Robert Finch, Secretary, United States Department of Health, Education and Welfare

429 F.2d 725, 139 U.S. App. D.C. 46, 1970 U.S. App. LEXIS 8804
CourtCourt of Appeals for the D.C. Circuit
DecidedJune 9, 1970
Docket23890_1
StatusPublished

This text of 429 F.2d 725 (The National Welfare Rights Organization v. The Honorable Robert Finch, Secretary, United States Department of Health, Education and Welfare National Welfare Rights Organization v. The Honorable Robert Finch, Secretary, United States Department of Health, Education and Welfare) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The National Welfare Rights Organization v. The Honorable Robert Finch, Secretary, United States Department of Health, Education and Welfare National Welfare Rights Organization v. The Honorable Robert Finch, Secretary, United States Department of Health, Education and Welfare, 429 F.2d 725, 139 U.S. App. D.C. 46, 1970 U.S. App. LEXIS 8804 (D.C. Cir. 1970).

Opinion

429 F.2d 725

The NATIONAL WELFARE RIGHTS ORGANIZATION et al., Appellants,
v.
The Honorable Robert FINCH, Secretary, United States Department of Health, Education and Welfare, et al.
NATIONAL WELFARE RIGHTS ORGANIZATION et al., Appellants,
v.
The Honorable Robert FINCH, Secretary, United States Department of Health, Education and Welfare.

No. 23787.

No. 23890.

United States Court of Appeals, District of Columbia Circuit.

Argued February 27, 1970.

Decided June 9, 1970.

Mr. John W. Douglas, Washington, D. C., for appellants. Messrs. Roger L. Rice and Stephen Wexler and Mrs. Florence Roisman, Washington, D. C., were on the brief for appellants.

Mr. Raymond D. Battocchi, Attorney, Department of Justice, with whom Messrs. Thomas A. Flannery, U. S. Atty., and Alan S. Rosenthal, Attorney, Department of Justice, were on the brief, for appellees. Mr. Nathan Dodell, Asst. U. S. Atty., also entered an appearance for appellees.

Mr. Norman K. Janes, Willimantic, Conn., William H. Clendenen, Jr., New Haven, Conn., filed a brief on behalf of Quinnipiac Welfare Rights Mothers, Farnum Courts Welfare Rights Mothers, Willimantic Welfare Rights Mothers, and Togetherness Is Everyone, as amici curiae.

Before BAZELON, Chief Judge, and WRIGHT and McGOWAN, Circuit Judges.

J. SKELLY WRIGHT, Circuit Judge:

In November 1969 the Department of Health, Education and Welfare announced that in December 1969 and January 1970 hearings would be held to determine whether the welfare laws of the states of Nevada and Connecticut respectively were in conformity with certain federal standards in the Social Security Act so that those states might continue to receive payments of federal aid for their state welfare assistance programs. Plaintiff-appellants, a national voluntary association of welfare recipients, state affiliate organizations in Nevada and Connecticut, and welfare recipients individually and in behalf of all welfare recipients and needy children1 requested that they be permitted to participate as parties in the hearings.2 When the request was refused, appellants sought injunctive relief in the District Court incident to their main action in the nature of a mandamus. Although this is an appeal from a denial of a preliminary injunction, we here decide the merits of the controversy in view of the expression of the parties that such a determination is desirable and since the issues are ripe for adjudication on this record.3

* The Social Security Act of 1935 established several grant-in-aid programs4 whereby any state at its option might apply for federal funds to allocate to its welfare assistance programs for certain statutorily specified categories of needy individuals and families.5 At present in order to participate in these programs, the state must submit the plans for its program in any of the categories to the Secretary of Health, Education and Welfare. The Secretary's duty is to measure the plan against standards which Congress has designated for each program. If the state plan meets the designated requirements, the Secretary "shall approve" it.6

Existing approved plans continue to bear the Secretary's scrutiny. He may discontinue payments if he finds that the plans, as written or as applied, no longer conform to federal standards. An administrative review procedure for testing continued conformity of an approved plan is provided. Before funds may be cut off the Secretary must "give reasonable notice and opportunity for hearing" to the state agency administering the plan. The Secretary has implemented this requirement in the Act by a regulation7 favoring informal negotiations between state officials and HEW representatives as an initial step toward conformity, with subsequent resort to formal hearings if resolution is not reached by informal means. Any state which objects to a determination of the Secretary arising out of negotiations or a hearing may seek review of that determination in the United States Court of Appeals for the circuit in which the state is located.8

Both Nevada and Connecticut have federally approved state plans funded under the Aid to Families with Dependent Children (AFDC) Program,9 which provides welfare assistance to children who are deprived of adequate parental support.10 The requirements section of the AFDC, 402, 42 U.S.C. § 602,11 was amplified in 1968 when Congress adopted several amendments to the Social Security Act12 with the result that states with AFDC plans were required to submit modified plans. When, even after informal negotiations,13 no amended plans were forthcoming from the states of Nevada and Connecticut, among others, the Administrator of the Social and Rehabilitation Service of HEW, who has been delegated responsibility for the administration of the AFDC program,14 initiated action. Nevada and Connecticut officials were notified by letters from the Administrator on November 14, 1969, that a hearing to determine the matter of continued conformity had been set for each state.15 In the letter of notification to Nevada welfare officials, the Administrator "anticipated" that the issues to be explored in the hearing would pertain to the state's cooperative plan with the United States Department of Labor's Work Incentive plan, the state's provision for the disregard of amounts of earned income when considering the need factor of a family, and its provisions for certain child care services.16 Connecticut's AFDC plan, according to the notification, may not properly implement federal disregard of income regulations, may lack a simplified plan for determining eligibility, may improperly exclude children eligible under federal standards, and may be deficient in its service programs for AFDC families and children.17

It was shortly after these notifications that public announcement of the impending hearings was made and that the Nevada appellants in correspondence with the Administrator requested that they be granted "status as a party"18 at the Nevada hearing. The request further expressed an interest in expanding the issues set down for hearing.19 A postponement of the hearing followed and appellants were sent a letter informing them of the postponement and of Nevada's willingness to negotiate in an effort to resolve the issues without hearing.

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429 F.2d 725, 139 U.S. App. D.C. 46, 1970 U.S. App. LEXIS 8804, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-national-welfare-rights-organization-v-the-honorable-robert-finch-cadc-1970.