This case concerns whether utility reimbursements provided under the Housing Act to low-income tenants should be treated as income when calculating eligibility and benefit amounts for food stamps under the Food Stamp Act. Plaintiffs, including state officials and individual recipients, challenged the Secretary of Agriculture's policy of including these payments as income, arguing that they qualify for statutory exclusions under 7 U.S.C. §§ 2014(d)(1) and 2014(d)(11) as non-cash benefits or energy assistance, and also raised Fifth Amendment due process claims. The court granted summary judgment to the plaintiffs, ruling that the Secretary's policy was impermissible. The core reasoning was that utility reimbursements defray energy costs that can be separated from other expenses, fall within the plain meaning and legislative history of the energy assistance exclusion, and that the policy frustrates congressional intent even under deferential review; the court also noted a subsequent clarifying statute but focused on the prior framework.
This case involves petitioner James F. Shaw, Sr.'s motion under 28 U.S.C. § 2255 to vacate his 1986 conviction and 25-year sentence for seven counts of carnal knowledge of his eleven-year-old foster daughter. Shaw claimed ineffective assistance of counsel because his attorney failed to include arguments in pre-trial Rule 412 motions about the victim's venereal disease and constitutional requirements for admitting evidence of her past sexual behavior with others to explain physical findings. The court denied the motion, holding that the venereal disease issue had already been resolved on direct appeal and thus could not be relitigated, and that counsel's performance was not deficient because the evidence was not constitutionally required and the failure to raise a meritless argument did not fall below an objective standard of reasonableness under Strickland.
This case involved a long-term employee suing his former employer for promised retirement benefits after nearly 25 years of work at an auto repair shop. The employer had orally promised a lump-sum payment at age 62 based on years of service, with conditions like no moonlighting and continued employment until retirement, but later canceled the arrangement. The court determined that the promise qualified as an ERISA employee pension benefit plan, making it enforceable under federal law. It reasoned that the informal, unwritten commitment still met ERISA criteria because a reasonable person could identify the benefits, beneficiaries, funding source, and procedures, and the employer had effectively established the plan by communicating it to employees. The court awarded the plaintiff either the present value of benefits with interest or a future payment at age 62.
This case concerns efforts to provide child support enforcement services under Title IV-D of the Social Security Act to Native American children with absent parents living on reservations in South Dakota. The court had previously directed the Department of Health and Human Services to negotiate directly with the tribes regarding potential Tribal Plans, but on reconsideration it modified that directive to instead require federal and state defendants to assist in negotiating cooperative agreements between the state and tribes for delivery of the services. The court reasoned that the statute and regulations contemplated only state plans and agreements with state courts and did not account for semi-sovereign tribal entities, so the agreements could ensure federal compliance without requiring tribes to alter their own laws. It denied the state defendants' separate motion to dismiss the case in light of the Supreme Court's Suter decision, viewing that issue as appropriate for appellate review.
In Dykes v. United States, the plaintiff, as administratrix of the estate of Ian Knife, brought a Federal Tort Claims Act action alleging that federal officials negligently failed to prevent Knife's suicide while in custody at the Hughes County Jail. The defendant moved to dismiss for lack of subject matter jurisdiction, arguing that the initial administrative claim filed with the U.S. Marshals Service was submitted in Naomi Dykes' individual capacity rather than as estate administratrix, violating 28 C.F.R. § 14.3(c). The court denied the motion, holding that the jurisdictional notice requirements of 28 U.S.C. § 2675(a) were satisfied because the claim provided sufficient information for investigation and a sum certain for damages, and that the regulation's capacity requirement affects only settlement opportunities, not the right to sue in federal court.
This case involved a Chapter 11 bankruptcy filed by debtors Michael and Shirley Cook, in which the Farmers Home Administration (FmHA) held the largest claim, split into secured portions on real estate and chattels plus a large undersecured portion, and had made an election under 11 U.S.C. § 1111(b) to treat its entire claim as secured. After the debtors prepaid the secured chattel debt in full and sought to discharge the associated liens, the FmHA argued that its § 1111(b) election prevented lien release until all plan payments, including on the undersecured claim, were complete. The district court affirmed the bankruptcy court's decision to discharge the chattel liens upon full payment of that secured claim but reversed its ruling on the undersecured claim payments. The core reasoning was that the § 1111(b) election did not block discharge of liens securing a fully paid allowed secured claim, while the plan's terms made the undersecured payments premature because real property payments had not yet been completed.
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