Stevens v. Hayward

No. 99-5963 (R.I. Super. Ct. Providence County Dec. 18, 2003); Clearinghouse Number: 53190

Description

Generic Denial Notices Regarding Public Benefits Violate Due Process

Abstract

A Rhode Island court held that computer-generated public assistance denial notices, which gave as reason for the denial only that “you failed to provide all required information” or “there are no eligible members in the Rhode Island medical assistance case,” violated constitutional due process rights and federal medical assistance and food stamp statutory requirements. Plaintiffs applied for food stamps and medical assistance. One plaintiff, whose application was denied because he failed to sign it, received a denial notice stating only that he had failed to give required information. The second plaintiff received a medical assistance denial notice stating only that there were no eligible members. Granting summary judgment for plaintiffs, the court found that the notices violated federal requirements that denial notices must cite the specific regulation supporting denial and that agencies must distinguish between failure and refusal to give information. The generic notices also violated state and federal due process rights: the lack of individualized reasons left applicants unable to craft meaningful arguments for hearing or for rebutting agency assertions on appeal. Inclusion of agency workers’ phone numbers in the notices did not cure the constitutional defect. The court ordered defendant Rhode Island Department of Human Services to assist households in obtaining verification; distinguish in its procedures between failure and refusal to give information; identify the specific information that an applicant failed to give and the relevant regulation if it sought to deny benefits on that basis; and reprogram its computerized notice system.

Additional Information

Attorney Information
Plaintiff represented by Gretchen Bath, R.I. Legal Services, 56 Pine St., 4th Fl., Providence, RI 02903; 401.274.2652
Docket Date
2003-12-18 06:00:00+00:00