Clifford v. Janklow
United States Court of Appeals for the Eighth Circuit
733 F.2d 534 (1984)
- Written by Samantha Arena, JD
Facts
South Dakota’s (defendant) 1983 version of its Low-Income Energy Assistance Program (LIEAP), implemented under the Low-Income Home Energy Assistance Act (LIHEAA), excluded people living in subsidized housing. After the exclusion was struck down by a district court, South Dakota implemented a revised plan that applied different eligibility rules depending on whether an applicant was a subsidized-housing resident. Households that did not live in subsidized housing were granted an amount covering an assigned percentage of heating expenses depending on income level and were not required to prove actual expenses to receive the allocated level of benefits. In contrast, residents of subsidized housing were deemed only “partially vulnerable” to heating costs because the shelter subsidies the residents received already incorporated heating expenses. To determine a Section 8 recipient’s level of LIEAP benefits, the state took the amount set aside for heating from the monthly Section 8 subsidy and multiplied by 12 to get the total yearly heat allowance. If the total exceeded the LIEAP benefit for a comparable nonsubsidized household, the Section 8 household was deemed ineligible for LIEAP. If the total was lower, the Section 8 household received the balance. Individuals living in subsidized housing (subsidized-housing residents) (plaintiffs) brought a class action, contending that the LIEAP violated the LIHEAA. The district court found in the subsidized-housing residents’ favor. The state appealed.
Rule of Law
Issue
Holding and Reasoning (Heaney, J.)
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