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.)
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 726,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead 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.Learn about our approachRead more about Quimbee
Here's why 726,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,700 briefs, keyed to 983 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.