Kapps v. Wings

404 F.3d 105 (2nd Cir. 2005)

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Nature of the Case

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Facts

Congress enacted a plan to home energy assistance to low-income families. States are given a block grant, which may be used for two primary purposes: 1) to assist poor families in meeting their regular heating2 costs and 2) to intervene in energy crises to prevent any interruption in needy households' heat. States may, but need not, choose to supplement federal funds with state monies, in order to ensure that all eligible households are provided with benefits. New York, like some other states, has opted not to supplement federal funds and hence provides benefits only to the extent that federal funding is available in any given program year. New York's Home Energy Assistance Program ('HEAP') was created in 1983, in order allow the state to take advantage of the federal block grant program. HEAP is administered jointly by the state and by local social service districts. The Office of Temporary and Disability Assistance ('OTDA') annually sets standard eligibility criteria and benefits levels for the forthcoming year. There are two categories of households which may be eligible for regular HEAP benefits: 1) 'categorically income eligible households'; and 2) 'income-tested households.' Once found eligible, a household's HEAP benefits allocation is determined in accordance with a complicated payment matrix, or point system. This 'payment matrix' takes into account such factors as family income, the energy burden ratio of the household, the amount of federal funds allocated for the year, and the presence of 'vulnerable' household members. Ds were required to process all HEAP applications within 30 business days. Average processing times for New York City HEAP applications have varied between 21 and 122 days. Applicants have 60 days from the date of the HEAP notice, during which they may request an administrative 'fair hearing' to challenge the agency's eligibility and/or benefits level determination. Ps filed a complaint alleging various violations of the federal Due Process Clause in Ds' administration of the New York City HEAP program. Specifically, Ps contend that the denial of the right to a fair hearing violated due process and the LIHEAA. Ps also claimed that the HEAP notices - by failing to provide information on how the applicant's benefits eligibility and allotment was calculated - did not meet the requirements of due process. Ps moved for summary judgment and class certification. The district court granted class certification, and gave summary judgment in part to Ps and in part to Ds. Ds appealed.