N.B. v. Sybinski

724 N.E.2d 1103 (2000)

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N.B. v. Sybinski

Indiana Court of Appeals
724 N.E.2d 1103 (2000)

Facts

In an effort to implement welfare reform, Peter Sybinski, the Secretary of Indiana Family and Social Services (defendant), requested US secretary of Health and Human Services (HHS) approval of waivers of Aid to Families with Dependent Children (AFDC) requirements. One waiver included a family-cap provision under which a family’s benefits would no longer automatically increase upon the birth of a new child. Under the cap, the reformed Temporary Assistance for Needy Families (TANF) benefits were not provided to children born 10 or more months after the family began receiving benefits. The automatic increase, however, was still granted in certain cases, including if the child did not reside with the parent. Indiana created a “control group” subject to AFDC and a “treatment group” subject to the reformed TANF program to measure the effects of the reform. N.B. (plaintiff) had two children and received AFDC benefits for three years. N.B.’s third child, L.K., was conceived despite N.B.’s use of birth control. N.B. did not receive a benefit increase upon L.K.’s birth because L.K. was born more than 10 months after N.B. started receiving benefits. N.B. filed suit, arguing that the family-cap rule violated due-process principles and the Equal Protection Clause of the Fourteenth Amendment because the rule treated children within the treatment group differently. The trial court granted summary judgment in Indiana’s favor. N.B. appealed.

Rule of Law

Issue

Holding and Reasoning (Garrard, J.)

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