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Waters-Haskins v. Human Services Department

New Mexico Supreme Court
210 P.3d 817 (2009)


New Mexico gave Hazel Waters-Haskins (plaintiff) food stamps for eight years when she did not qualify. Waters-Haskins fostered her grandchildren until adopting them in 1997. The state paid her a foster-parent subsidy beforehand, and an adoptive-parent subsidy afterward. She correctly reported both subsidies in her food-stamp applications, including the status change. Only the foster-parent subsidy, not the adoptive-parent subsidy, was deductible from her income for eligibility purposes. But the New Mexico Human Services Department (defendant) kept deducting her adoptive-parent subsidy and giving her food stamps until 2004. Upon discovering the error, the department correctly calculated her total income at $1446 a month (including social security and disability income), disqualifying her for food stamps. The department assessed an overpayment claim for the preceding 11-month period and sent a letter asserting Waters-Haskins owed the department $4,476. Waters-Haskins requested an administrative hearing, but the judge supported the department’s claim. Waters-Haskins appealed, asserting equitable estoppel barred the department from recovering the overpayment. The appellate court reversed but remanded, reasoning the equitable-estoppel defense was premature unless the department failed to compromise the claim. Both sides appealed, and the New Mexico Supreme Court granted review.

Rule of Law


Holding and Reasoning (Maes, J.)

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