Hill v. Utah State Department of Workforce Services

William Hill (plaintiff), a disabled, elderly individual, received a $45,000 inheritance from his mother’s estate. Hill transferred the $45,000 to the Utah SNAP Fund, Inc. (the trust), the state’s pooled fund supplemental needs trust. The trust was comprised of two main accounts: (1) the pooled investment account that held all beneficiaries’ deposited funds; and (2) a sub-trust checking account into which investment account funds were periodically transferred to cover expenses incurred by trust beneficiaries. Trust beneficiaries, like Hill, had no control over the distribution or investment of trust funds, and reimbursement for incurred expenses was entirely in the trustee’s discretion. Assets held in the trust were excluded from consideration when a trust beneficiary’s eligibility for government assistance programs, like the Food Stamp Program (FSP), was assessed. After transferring the $45,000 to the trust, Hill applied for food stamps. Because Hill was elderly, his FSP eligibility was assessed using the net-income standard. The FSP denied Hill’s application because his net income exceeded the eligibility threshold. In calculating Hill’s net income, FSP included: (1) intra-trust transfers made by the trustee from the investment account to the sub-trust checking account; and (2) reimbursements Hill received from the trust covering utility bills, life insurance premiums, medical expenses, a bus pass, and clothing costs. Hill appealed FSP’s decision, and both the Utah State Department of Workforce Services (department) (defendant) and an administrative-law judge (ALJ) confirmed the denial. Hill then sought judicial review in federal district court.