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Khrapunskiy v. Doar
Index No. 404175/04, 2005 NYSlipOp 51462(U), (N.Y. Sup. Ct. N.Y. County Aug. 11, 2005) ; Clearinghouse Number: 55956
Description
New York State May Not Deny, Based on Immigration Status, Assistance to Indigent and Lawfully Residing Elderly, Blind, or Disabled Persons
Abstract
Granting plaintiffs’ summary judgment motion, the trial court
held that State’s failure to provide to plaintiffs and
class—based on their immigration status—assistance at
the standard of need for the elderly, blind, and disabled set forth
in New York law violated State’s constitutional duty to
support the indigent and plaintiffs’ state and federal equal
protection rights. New York law provides that the needs of those
whose income falls below that standard will be met through the
additional state payments program. Plaintiffs were indigent and
lawfully residing elderly, blind, or disabled persons who became,
because of their immigration status, ineligible for Supplemental
Security Income (SSI) and additional state payment benefits. Their
SSI benefits were terminated in 1996 when Congress rendered certain
lawful immigrants ineligible for SSI benefits; their additional
state payment benefits were terminated because the state
legislature implemented the same restrictions in that program. In a
state-court class action, plaintiffs challenged State’s
failure to provide them and others similarly situated with benefits
at the level that State determined to be generally appropriate for
the indigent aged, blind, and disabled. After rejecting
State’s nonjudiciability and standing arguments, the court
found that State was denying benefits to plaintiffs on the basis of
an eligibility condition having nothing to do with need and
concluded that, based on Aliessa v. Novello, 754 N.E.2d 1085 (N.Y.
2001) (Clearinghouse No. 52,429), State’s constitutional duty
to support the indigent prevented State from ceasing to pay
benefits at the standard of need level required by state law merely
because the federal government no longer paid. Also based on
Aliessa, the court found that excluding—based on immigration
status—some among the indigent aged, blind, and disabled from
receiving this level of benefits violated their equal protection
rights.
