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.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 218,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,100 briefs, keyed to 189 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.