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Quattlebaum v. Kelly

October 20, 1994

CARRIE QUATTLEBAUM, ET AL, APPELLANTS
v.
SHARON PRATT KELLY, MAYOR OF THE DISTRICT OF COLUMBIA, ET AL, APPELLEES



Appeal from the Superior Court of the District of Columbia; (Hon. Ronald P. Wertheim, Trial Judge)

Before Ferren and Sullivan, Associate Judges, and Pryor, Senior Judge.

The opinion of the court was delivered by: Sullivan

SULLIVAN, Associate Judge: This is an appeal from the trial court's order denying appellants' motion for summary judgment and granting appellees' motion for summary judgment. Appellants' principal contention on appeal in this class action lawsuit *fn1 for declaratory, injunctive, and monetary relief is that appellees, the District of Columbia and its highest-ranking officials, *fn2 improperly enacted emergency legislation *fn3 effective July 1, 1991, reducing, to October 1, 1989 levels, recipients' entitlement to benefits under Aid to Families with Dependent Children ("AFDC"). *fn4

The three issues raised on appeal are: (1) whether the District's failure to reassess the current minimum needs of its AFDC recipients, prior to enacting the benefit reductions contained in the 1991 Act, constituted a violation of D.C. Code § 3-205.44 (b) (1988); (2) whether the District's express recognition that the AFDC benefit reduction would be partially offset by correlative increases in food stamp benefits violated 7 U.S.C. § 2017 (b) (1988); and (3) whether the District's notice advising AFDC recipients of the benefit reductions, which failed to provide individual computations of new benefit levels and failed to indicate the circumstances under which individuals affected by the cuts could obtain a hearing on computational grounds, violated D.C. Code § 3-205.55 (c) (1988), 45 C.F.R. § 205.10 (a)(4)(iii) (1992), and the Due Process Clause of the Fifth Amendment to the Constitution.

We find persuasive the second and third arguments raised on appeal. *fn5 Accordingly, we reverse the orders of the trial court denying summary judgment in favor of appellants and granting summary judgment in favor of appellees and remand the case to the trial court for further proceedings consistent with this opinion.

I.

Facts

On March 1, 1991, during a fiscal crisis, the Mayor submitted to the Council of the District of Columbia ("Council") her revised Fiscal Year 1991 and her Fiscal Year 1992 budget proposals. The cumulative effect of the Mayor's budget proposals would be to permanently suspend the previously automatic annual AFDC cost-of-living adjustment ("COLA") and, further, to reduce individual AFDC recipients' entitlement to benefits by 4.5 percent across-the-board, rolling them back to 1989 levels.

On March 18 and 19, 1991, the proposed budget was introduced in the Council and referred to the Committee on Human Services ("the Committee"). In its deliberations, the Committee did not attempt to assess the minimum needs of AFDC recipients. Nonetheless, the Committee issued a REPORT OF THE COUNCIL OF THE DISTRICT OF COLUMBIA COMMITTEE ON HUMAN SERVICES ON BILL 9-159, PUBLIC ASSISTANCE ACT OF 1982 BUDGET CONFORMITY AMENDMENT ACT OF 1991 (Apr. 25, 1985), D.C. Law 9-27, signed by Chairman H.R. Crawford (hereinafter "Crawford Committee Report"), which recommended that the Council adopt the Mayor's revised Fiscal Year 1991 and her Fiscal Year 1992 budget proposals as amended. The Committee's proposed budget legislation, the AFDC portion of which was ultimately adopted by the full Council, amended the Mayor's proposal, inter alia, by suspending the automatic annual COLA provision until October 1, 1993. The budget legislation did not totally repeal the COLA provision or leave the determination for allowing the COLA up to the Mayor to effectuate by rulemaking authority. See Crawford Committee Report at 6. The "Background and Need" section of the Crawford Committee Report stated with regard to the proposed reduction in AFDC benefits that the 1991 Act would "suspend the automatic consumer price indexing of public assistance payments to recipients of the AFDC . . . program[] until 1993" and "reduce the level of payments to all recipients of public assistance programs [including AFDC], beginning July 1, 1991, to the payment level used on October 1, 1989[.]" Crawford Committee Report at 3.

In the same section, the Crawford Committee Report noted that "the loss of benefits will be offset by an increase in the monthly food stamps allotment for which individuals and families are eligible." That is to say, under federal law, food stamp allotments automatically increase as an eligible recipient's income (from AFDC funds or otherwise) goes down. *fn6 The Report presented the following chart as an example of "the impact [of the AFDC benefits reduction] by family size":

Food Stamp

Household FY 90 FY 91 AFDC Decrease *fn7 Increase

1 $258 $270 $12 $4

2 321 336 15 5

3 409 428 19 6

4 499 522 23 7

Crawford Committee Report at 6. Also, during a meeting of the Committee held on April 25, 1991, to consider and mark up the proposed budget legislation and the Crawford ...


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