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Robidoux v. Celani

United States Court of Appeals for the Second Circuit
987 F.2d 931 (1993)


The Vermont Department of Social Welfare (Department) (defendant) administered public assistance programs, including the Food Stamp Program, Aid to Needy Families with Children Program (ANFC), and Supplemental Fuel Assistance Program (Fuel Assistance). Federal regulations required the Department to make decisions on applications for benefits within 30 days. The Department failed to timely process applications for food stamps and/or ANFC benefits sought by Julie Robidoux, Kathleen Rock, and Margaret Bevins (plaintiffs). Robidoux filed a 28 U.S.C. § 1983 action in federal court against the Department, in which Rock and Bevins intervened. Together, the plaintiffs sought to represent a class of all current and future individuals whose applications for food stamps, ANFC benefits, and/or fuel assistance were unlawfully delayed by the Department. After the case was filed, all three plaintiffs received retroactive benefits. In support of class certification, the plaintiffs produced official documents showing delays over the previous year affecting 22 to 133 applicants for food stamps or ANFC benefits per month. The plaintiffs lacked records on processing times for fuel assistance benefits, because that program was seasonal. The district court denied the plaintiffs’ motion for certification on the grounds of (1) failure to show joinder was “impossible”; (2) failure to meet the typicality requirement, because the plaintiffs lacked personal claims regarding the Fuel Assistance Program; and (3) mootness. The plaintiffs appealed.

Rule of Law


Holding and Reasoning (Peckham, J.)

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