Lamberton v. Shalala

857 F. Supp 1349 (1994)

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Lamberton v. Shalala

United States District Court for the District of Arizona
857 F. Supp 1349 (1994)

Facts

Under the 1982 Omnibus Budget Reconciliation Act (OBRA), the secretary of the US Department of Health and Human Services (the secretary) (defendant) proposed a rule establishing a $1,500 limit on the equity a family may own in a vehicle while still maintaining Aid to Families with Dependent Children (AFDC) eligibility. In setting the limit, the secretary relied on a 1979 study conducted by the Food and Nutrition Service (FNS) that concluded that most food-stamp recipients did not have an equity interest in a vehicle that exceeded $1,500. The secretary believed the FNS study conclusion could reasonably be used to create the AFDC limit because food-stamp recipients were generally less impoverished than AFDC recipients. Karen Lamberton (plaintiff) reapplied for AFDC benefits after her husband was imprisoned and Lamberton lost her home. Lamberton’s application was denied on the basis that she owned a $4,375 interest in a vehicle. Lamberton filed suit, challenging the equity limit’s validity.

Rule of Law

Issue

Holding and Reasoning (Roll, J.)

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