As we explained in our case summary, the question in this case was whether the Office of Temporary and Disability Assistance (OTDA) properly calculated petitioner’s income in determining her eligibility for food stamps benefits by including child support payments that petitioner received to support two of her children. The Court (Wilson, J.) held that OTDA’s calculation was proper and confirmed the agency’s determination, but for a reason other than the one given by the Second Department.
To begin, the Court explained why the Second Department’s decision was incorrect. That court had held that the child support payments petitioner received were income of the supported children. But the court also held that the payments should be included in household income because the supported children were students who were ineligible for SNAP because they failed to comply with a work requirement. And people who are ineligible due to failure to comply with a work requirement must have their income counted toward household income.
This was incorrect, the Court explained, because the student-children were not ineligible due to their failure to comply with a work requirement; they were ineligible due their failure to comply with separate rules governing the eligibility of students. As a result, the provision stating that household income must include the income of people who are ineligible for noncompliance with a work requirement did not apply. Instead, a provision specifically dealing with how to count the income of ineligible students applied. And that provision mandated that the ineligible-student income be excluded from household income, rather than included in household income as the Second Department had concluded.
The Court then turned to the main question in the case: were the child support payments that petitioner received her income or the income of her ineligible-student children for SNAP purposes? Here, the Court deferred to OTDA’s determination that the child support payments were petitioner’s income. The agency got deference not because it was interpreting a statute or regulation; as the Court explained, no statute or regulation addressed this issue. Instead, deference was appropriate because the question came “down to a policy decision within the cooperative federalism framework of a national program committed to state administration.” In effect, the Court held that this was a decision left to the discretion of state administrators. And the Court observed that a state administrator could rationally decide the issue either way, as evidenced by the fact that states had gone both ways on the question. (For instance, Alaska treated child support payments as income of the person receiving them; Florida treated those payments as income of the child.) It was therefore not irrational for OTDA to decide the issue the way it did, and the Court deferred to that decision.
Return to the case page for Matter of Leggio v. Devine.