Madden v. Oklahoma

523 F.2d 1047 (1975)

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Madden v. Oklahoma

United States Court of Appeals for the Tenth Circuit
523 F.2d 1047 (1975)

Facts

Before 1974, the federal food-stamp program permitted each participating state to choose in which political subdivisions the state would conduct the program. A 1973 amendment to the program under 7 U.S.C. § 2019(e), however, required each state to “include every political subdivision in the [s]tate,” unless the state was able to demonstrate to the United States Department of Agriculture (USDA) that extending the program to a particular subdivision would be impossible or impracticable. Additionally, Oklahoma law required political subdivisions or counties to pay the state administrative costs of distributing food stamps. Specifically, Oklahoma statute required the board of county commissioners to reimburse the Oklahoma Public Welfare Commission for a prorated share of the total cost of food-stamp distribution. However, the food-stamp program was not implemented in Beaver County, Oklahoma. Bertha Madden and a group of Beaver County residents eligible for food stamps (plaintiffs) filed suit against the State of Oklahoma (defendant) to compel the state to implement the food-stamp program in the county. The state asserted that if the court were to find in the residents’ favor, judgment must instead be entered against the board of county commissioners of Beaver County. The trial court concluded that participating states must conduct the food-stamp program in all of the state’s political subdivisions and that Beaver County was required to pay the state administrative costs of the program. The board of county commissioners of Beaver County appealed, contending that language in 7 U.S.C § 2019(e) allowed states to opt out of conducting the program in particular subdivisions. Beaver County further contended that it should not be required to pay the administrative costs of the food-stamp program.

Rule of Law

Issue

Holding and Reasoning (Lewis, C.J.)

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