Weaver v. New Mexico Human Services Department

123 N.M. 705, 945 P.2d 70 (1997)

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Weaver v. New Mexico Human Services Department

New Mexico Supreme Court
123 N.M. 705, 945 P.2d 70 (1997)

Facts

The New Mexico Human Services Department (HSD) administers the General Assistance (GA) program, which provides financial assistance to dependent children, disabled adults ineligible for Social Security Income (SSI), and others who are ineligible for any federal-assistance program. To reduce spending, HSD promulgated Financial Assistance Program (FAP) 419, which limited the duration of GA benefits for disabled adults to a maximum of 12 months. No 12-month limit was imposed for other eligible groups. Disabled recipients of GA benefits who would no longer be eligible upon the implementation of FAP 419 (the recipients) (plaintiffs) sued, arguing that the rule violated Title II of the Americans with Disabilities Act (ADA). The district court concluded that FAP 419 violated the ADA as a matter of law. HSD appealed, arguing that the GA program consists of three separate programs, and amending one program does not violate the ADA because the ADA does not mandate that different programs provide equivalent benefits.

Rule of Law

Issue

Holding and Reasoning (Baca, J.)

Concurrence (Minzner J.)

Concurrence (Franchini, J.)

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