State of New York v. Lyng
United States Court of Appeals for the Second Circuit
829 F.2d 346 (1987)
- Written by Samantha Arena, JD
Facts
Under the Food Stamp Act of 1977 (the act), a household is eligible to receive food stamps equal to the estimated monthly cost of food minus 30 percent of the household’s income. The US Department of Agriculture (the department) includes public-assistance grants as part of a household’s income for eligibility calculation, except if specifically excluded by statute. The State of New York (plaintiff) provides a supplemental “restaurant allowance” to individuals who lack the facilities or ability to cook at home. The secretary of the department, Richard Lyng (the secretary) (defendant), ruled that the state must include the restaurant allowance as income when calculating food-stamp benefit amounts, resulting in lesser food-stamp benefits for individuals who receive the allowance. Valerie Rodriguez’s family (plaintiffs) lived in a shelter without cooking facilities and received food stamps and the restaurant allowance. The State of New York, New York City, and Rodriguez filed suit seeking a preliminary injunction preventing the secretary from effectuating the income ruling, contending that the ruling was inconsistent with (1) the language of the regulations providing for inclusion of reimbursements for “food eaten at home,” (2) legislative history evidencing Congress’s intent to define income in a way that reflects food-purchasing power, and (3) the exclusion of reimbursement under similar programs, including emergency-shelter payments and Federal Emergency Management Assistance (FEMA) payments made to individuals after a disaster. The district court denied the motion for a preliminary injunction. The state, city, and Rodriguez appealed.
Rule of Law
Issue
Holding and Reasoning (Cardamone, J.)
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