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Medora v. Colautti

decided: July 24, 1979.

MEDORA, CLAIRE; COPEN, ERNA; HENRICH, DOROTHY; AND ALL OTHERS SIMILARLY SITUATED,
v.
COLAUTTI, ALDO, INDIVIDUALLY AND IN HIS CAPACITY AS SECRETARY OF THE DEPARTMENT OF PUBLIC WELFARE; MARTINO, SAMUEL R., INDIVIDUALLY AND IN HIS CAPACITY AS EXECUTIVE DIRECTOR OF THE LANCASTER COUNTY BOARD OF ASSISTANCE; LINK, SUSAN, INDIVIDUALLY AND IN HER CAPACITY AS CASEWORKER FOR THE LANCASTER COUNTY BOARD OF ASSISTANCE, ALDO COLAUTTI AND SAMUEL R. MARTINO, APPELLANTS



APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA; D.C. Civil No. 78-1549

Before Seitz, Chief Judge, and Hunter and Garth, Circuit Judges.

Author: Hunter

Opinion OF THE COURT

1. The Pennsylvania Department of Public Welfare (DPW) seeks review of a district court order which enjoins the application of a DPW regulation*fn1 to appellees and others similarly situated. Because the challenged regulation establishes a classification which contravenes the equal protection clause, the district court order will be affirmed.

I.

2. Pennsylvania provides general assistance welfare benefits to "all of its needy and distressed" citizens.*fn2 DPW administers the benefit program and is authorized to promulgate rules and regulations which are consistent with the program's goals.*fn3 The federal government administers a program of Supplemental Security Income benefits (SSI) which aids the blind, aged and disabled. The SSI need criteria are stricter in practice than are those which govern the Pennsylvania general assistance program.*fn4

3. The challenged regulation, P.A.E.M. § 297.1(e),*fn5 provides that the blind, aged, or disabled must apply for federal SSI benefits prior to applying for state general assistance benefits. It further provides that if a person is found Not to be blind, aged, or disabled (and hence unqualified for SSI) that person may then apply for general assistance. However, if the person is found to be blind, aged, or disabled, yet ineligible for SSI for some other reason (such as income or resources over the maximum limits) that person is Barred from applying for general assistance, Even if the person Would still qualify as needy under the applicable general assistance criteria. Thus, P.A.E.M. § 297.1(e) bars all aged, blind, or disabled persons from receiving general assistance, including those who are in fact needy under the Pennsylvania welfare code yet ineligible for benefits under the federal program. "The incongruity arises that if (such persons) were less disadvantaged (i. e. not blind, not aged, not disabled) they would be eligible for (general assistance), but since they are more disadvantaged they are not (eligible for general assistance)". Medora v. Colautti, No. 78-1549, slip op. at 2 (E.D.Pa. Aug. 4, 1978).

4. All of the appellees were denied SSI benefits for reasons unrelated to their recognized disabilities*fn6 and were subsequently declared ineligible for general assistance because of that denial. The district court concluded, "It is undisputed that if plaintiffs were not disabled and therefore not required to apply for federal support, they would be eligible for the state assistance." Id.

5. The district court found that the regulation promulgated by DPW was arbitrary, capricious and an abuse of discretion and that it frustrated the purpose of Pennsylvania's welfare statute. The court concluded that in applying the regulation and denying appellees benefits which the legislature intended they receive, DPW had violated the due process rights of the appellees. While we will affirm the district court's order, we need not reach the due process issue, since we hold that the DPW regulation establishes a classification which contravenes the equal protection clause.*fn7

II.

6. Under traditional equal protection analysis, we ask whether the challenged classification*fn8 is rationally related to a legitimate governmental interest. United States Department of Agriculture v. Moreno, 413 U.S. 528, 533, 93 S. Ct. 2821, 37 L. Ed. 2d 782 (1973). The articulated purpose of the statute is to provide "assistance to all of (the State's) needy and distressed." Pa.Stat.Ann. tit. 62, § 401 (Purdon 1968). The statute does not establish any eligibility criterion other than need; if anything it exhibits a special solicitude for the disabled. See note 3 Supra. The challenged DPW classification, however distinguishes between the non-disabled needy and the disabled needy, providing aid to the former and denying it to the latter. See note 4 Supra. A classification such as this one "must be reasonable, not arbitrary, and must rest upon some ground of difference having a fair and substantial relationship to the object of the legislation, so that all persons similarly circumstanced shall be treated alike." Reed v. Reed, 404 U.S. 71, 76, 92 S. Ct. 251, 254, 30 L. Ed. 2d 225 (1971), Quoting Royster Guano Co. v. Virginia, 253 U.S. 412, 415, 40 S. Ct. 560, 64 L. Ed. 989 (1920). We hold that P.A.E.M. § 297.1(e) falls far short of this standard. It ignores the common denominator of need, and creates a classification that bears no relation to the legislatively declared purpose of the general assistance program. Indeed, by excluding some persons from general assistance despite their undisputed qualification as needy, the challenged regulation actually frustrates the object of Pennsylvania's welfare statute.

7. The classification would still withstand equal protection scrutiny if it rationally furthered some legitimate governmental interest other than that specifically stated in the Pennsylvania legislature's declaration of intent. United States Department of Agriculture v. Moreno, 413 U.S. 528, 534, 93 S. Ct. 2821, 37 L. Ed. 2d 782 (1973); Williams v. Wohlgemuth, 366 F. Supp. 541, 547 (W.D.Pa. 1973), Aff'd. 416 U.S. 901, 94 S. Ct. 1604, 40 L. Ed. 2d 106 (1974). This is a two-part test: the government interest must be legitimate And the challenged classification must be rationally related to the furtherance of that interest.

8. DPW advances three governmental interests to which it claims the challenged regulation is rationally related. First, the regulation avoids the administrative inconvenience of the state having to assess independently a disabled person's need where the federal government has already made a determination. Second, the regulation encourages parties who may be eligible for SSI benefits to apply for them, with the result that state funds are preserved. Third, the regulation establishes a two-tiered system, which leaves to the federal government the task of supporting blind, aged and disabled citizens and allows DPW to provide for the remaining needy. It is by no means obvious that the cumulative weight of these goals is sufficient to make out a legitimate government interest.*fn9 We need not decide the question, however, since even if the three governmental interests presented by DPW are legitimate the challenged regulation fails rationally to further those interests.

9. First, in regard to the claim of administrative convenience, since the state and federal governments administer programs with different eligibility criteria, it is irrational to allow a decision based on the stricter federal law to control a decision which is supposed to be based on the more generous state code. DPW must independently assess need because it has independently (and differently) defined need. By incorporating the SSI decisions as its own, DPW is in the wholly unreasonable position of declaring disabled persons to be not needy under ...


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