Ward v. Thomas

207 F.3d 114 (2d Cir. Mar. 24, 2000) ; Clearinghouse Number: 50751

Description

Second Circuit Holds That Eleventh Amendment Bars Federal Court Challenge to Amendment Reducing Benefits from Aid to Families with Dependent Children

Abstract

The Second Circuit held that the Eleventh Amendment barred a federal court action by a subclass of Aid to Families with Dependent Children (AFDC) beneficiaries because even though the subclass framed its relief in prospective terms the relief was retrospective. A 1995 Connecticut statutory amendment reduced benefits payable under the former AFDC program to beneficiaries who also received housing subsidies. In a suit against defendant-appellant Commissioner of Connecticut Department of Social Services, a class of AFDC beneficiaries alleged that the planned reduction was enacted without timely and adequate notice. Those claims were resolved. Here a subclass of children whose benefits were reduced under the amendment because they lived with a nonlegally responsible adult caretaker who received a housing subsidy sought correction of past underpayments. The district court would not allow commissioner to impute to the subclass the housing subsidies received by the children’s nonlegally responsible caretakers. The Second Circuit found Green v. Mansour, 474 U.S. 64 (1985), controlling. In Green, after Congress amended relevant law on the calculation of benefits, AFDC recipients had no remaining claims based on the calculation of present or future benefits; they were left with a claim for a declaration that the state’s past conduct violated federal law and a claim for notice relief. The Supreme Court held that the Eleventh Amendment barred federal courts from issuing declaratory or notice relief: although the recipients framed their prayer for relief in prospective terms, the effect of what they sought would be retrospective because the state no longer was violating federal law. Noting that the 1999 welfare act terminated the AFDC program, the Second Circuit concluded that the Eleventh Amendment barred the claims of this subclass for the same reasons as in Green.

Additional Information

Attorney Information
Plaintiff-appellees represented by Kathleen Sullivan, Jerome N. Frank Legal Services Org., P.O. Box 209090, New Haven, CT 06520 (203.432.4800); Shelly White, New Haven Legal Assistance Ass’n, 426 State St., New Haven, CT 06510 (203.946.4811).
Docket Date
2000-03-24 00:00:00+00:00