Williston v. Eggleston

No. 04 Civ. 4454 (RWS) (S.D.N.Y. April 16, 2008); Clearinghouse Number: 55975

Description

Settlement Agreement Reached in Suit Challenging Delay in Processing of Food Stamp Applications As Violation of Section 1983; District Court Had Held Food Stamp Act Creates Private Right of Action Under Section 1983, No Eleventh Amendment Bar to Reprocessing Applications

Abstract

The district court denied the motion of defendants—New York City Commissioner of Human Resources and New York State Commissioner of Temporary and Disability Assistance—to dismiss plaintiff food stamp applicants' class action complaint. Plaintiffs filed suit under 42 U.S.C. § 1983; they alleged that defendants deterred and discouraged people from filing food stamp applications at nonpublic assistance food stamp offices and failed to provide timely food stamps to eligible individuals and that State failed to fulfill its obligation under federal law to oversee and supervise City's administration of the Food Stamp Program. City moved to dismiss, claiming that plaintiffs did not have a private right of action under Section 1983 and lacked standing. State contended that the complaint should be dismissed due to the Eleventh Amendment and on other grounds. The court described "whether the [Food Stamp Act] creates a private right of action enforceable under 42 U.S.C. § 1983" as a "difficult issue" but found that the Act and implementing regulations met the tests for enforceability set forth in Blessing v. Freestone, 520 U.S. 329 (1997) (Clearinghouse No. 50109), and Gonzaga University v. Doe, 536 U.S. 273 (2002)(Clearinghouse No. 54643). The court said that the statutory and regulatory provisions at issue did not have an "aggregate focus" but rather "establish specific rights for individual households." Regarding State's claim that plaintiffs were seeking retrospective relief barred by the Eleventh Amendment, the court said that plaintiffs were seeking not retroactive money damages but the reprocessing of their applications for when their benefits were wrongly denied; this constituted a request for injunctive relief.

Additional Information

Attorney Information
Plaintiffs represented by Wendy Bach, The Urban Justice Center Homelessness Outreach Prevention Project, 666 Broadway, 10th Floor, New York, NY (10012)(646.602.5640); Elissa Devins, Yisroel Schulman, Randal Jeffrey, New York Legal Assistance Group, 130 E. 59th St., 14th Floor, New York, NY 10022 (212.750.0800).
Docket Date
2008-04-17 00:00:00+00:00
Attorney Email
edevins@nylag.org