Weston v. Cassata

The federal Welfare Reform Act of 1996 made changes to existing welfare law, including instituting the Temporary Assistance to Needy Families (TANF) program. To receive federal funds to provide TANF assistance, states had to enact legislation restricting welfare relief to recipients who complied with the amended federal welfare requirements. In 1997, Colorado enacted the Colorado Works Program Act (CWPA), overseen by the Colorado Department of Human Services (CDHS). Under the CWPA, participants who complied with program requirements would receive assistance. Participants who failed to comply would be sanctioned with a decrease in assistance. CDHS regulations provided that before sanctions could be imposed, the participant had to receive a written notice that described the sanction, explained the basis for the county’s decision, detailed the appeal procedure, and provided various other information. Frances Weston and other welfare-benefit recipients in Adams County, Colorado (collectively, the recipients) (plaintiffs) brought an action against the Adams County Board of Social Services and social-services director Donald Cassata (collectively, the county) (defendants). The recipients asserted that they had received sanction notices that did not fully or accurately explain the county’s sanction decisions or the appeal process. For example, some sanction notices did not state the sanction amount, did not describe the sanction’s effects, and gave an improper time frame to challenge the decision. The trial court received evidence indicating that the county typically reinstated benefits to recipients who disputed their sanctions, yet the county continued to use the same inadequate sanction notices. The court concluded that the county’s sanction notices were legally inadequate and that the county had deprived the recipients of due process. The county appealed, asserting that the recipients had not been deprived of due process because (1) the recipients had no property interest in welfare benefits, and (2) the notice had informed the recipients of the reasons for the proposed sanctions.