White v Roughton

WHITE v. ROUGHTON February 27, 1976 | Per Curiam | Appeal | Non-delegation Doctrine SUMMARY: Roughton, without written notice and explanation, terminated the general assistance received by White and Walker, and denied the application for the same by Silagy without informing her of the reasons for the denial of her application. They filed a complaint against Roughton, alleging that the latter determines eligibility arbitrarily, without any established written standards and regulations. The Court held that the lack of established standards and regulations for the determination of one’s eligibility for the general assistance is violative of due process. Moreover, Roughton failed to give plaintiffs adequate notice and an evidentiary hearing before their benefits were terminated, as well as state the reason for the denial of the application. DOCTRINE: Due process requires that welfare assistance be administered to ensure fairness and freedom from arbitrary decision-making as to eligibility. Fair and consistent application of eligibility requirements, requires established written standards and regulations. FACTS: 1. C. Vaughn Roughton, as the supervisor of the town of the City of Champaign Township, administers the general township assistance program which provides locally collected taxes for distribution as welfare to needy township residents. He terminated the assistance being received by Leon White and Elester Walker and denied the application for assistance of Beatrice Silagy. 2. White: received general assistance in the form of “food orders” for 5 periods of 1 week each in 1974. His last allotment was given on Oct. 8, 1974, and was subsequently terminated thereafter without any written notice or explanation as to the reason for the termination. He was also not informed of his right to appeal or how to institute such appeal. 3. Walker: was provided food assistance for $14 on Aug 23, 1974, and rent assistance for $65 from Oct 1-Nov 1, 1974. Subsequently, his assistance was terminated without written notice and without informing him of his right to appeal. 4. Silagy: applied for township general assistance on at least 3 occasions in 1974, but was denied of assistance without being informed of the reasons for the rejection of her application nor of her right to appeal. 5. Plaintiffs claim that Roughton: (1) operates the general assistance welfare program without published standards for eligibility or the amount of aid given; (2) terminates general assistance without giving the recipient notice and a hearing prior to that termination; (3) denies applications for general assistance welfare without giving the applicant notice and a hearing after the denial of the

application; (4) fails adequately to inform recipients and applicants of their right to appeal. ISSUE/S: WoN plaintiffs’ right to due process has been violated. – YES. HELD/RULING: REVERSED and REMANDED with directions. RATIO: 1. Procedural due process requires that welfare recipients must be provided with adequate notice and an evidentiary hearing before benefits may be discounted (Goldberg v. Kelly). 2. Moreover, due process requires that welfare assistance be administered to ensure fairness and freedom from arbitrary decision-making as to eligibility. Federally subsidized public assistance is governed by statute and extensive regulations. The Illinois Public Aid Department maintains specific regulations governing procedures and standards to determine eligibility. Defendant Roughton is apparently not bound by the regulations of the Illinois Public Aid Department. Certain basic eligibility requirements, however, are provided in the General Assistance statute itself. 3. Defendant Roughton as administrator of the general assistance program has the responsibility to the program to ensure the fair and consistent application of eligibility requirements. Fair and consistent application of such requirements requires that Roughton establish written standards and regulations. 4. At the hearing in the district court on the preliminary injunction, defendant Roughton admitted that he and his staff determine eligibility based upon their own unwritten personal standards. Such a procedure, vesting virtually unfettered discretion in Roughton and his staff, is clearly violative of due process. 5. The district court erred by failing to consider the relevant evidence presented at the hearing on the preliminary injunction. At issue was whether plaintiffs’ procedural due process rights were violated by the method by which they were denied general assistance, not whether they were entitled to the same. 6. Defendants’ contention that the hearing in the district court provided plaintiffs sufficient due process cannot be sustained. The requirements of due process include a determination of the issues according to articulated standards. The lack of such standards in this case deprives any hearing, whether before an agency or a court, of its meaning and value as an opportunity for the plaintiffs to prove their qualifications for assistance.