Atkins v. Parker
Annotate this Case
472 U.S. 115 (1985)
U.S. Supreme Court
Atkins v. Parker, 472 U.S. 115 (1985)
Atkins v. Parker
Argued November 27, 1984
Decided June 4, 1985
472 U.S. 115
In 1981, Congress amended the Food Stamp Act to reduce from 20 percent to 18 percent the earned income disregard used in computing eligibility for food stamps. Thereafter, the Massachusetts Department of Public Welfare (Department) mailed a notice to all food stamp recipients in the State with earned income advising them that the reduction in the earned income disregard might result in either a reduction or termination of their benefits, that they had a right to request a hearing, and that their benefits would be reinstated if a hearing was requested within 10 days of the notice. Petitioners in No. 83-6381 (hereafter petitioners), recipients of the notice, brought a class action in Federal District Court, alleging that the notice was inadequate and seeking injunctive relief. After the court issued a temporary injunction, the Department sent a second notice similar to, but somewhat more extensive than, the first notice. Petitioners also attacked the adequacy of this notice. The court again ruled in petitioners' favor and held that the notice violated the Due Process Clause of the Fourteenth Amendment. The Court of Appeals agreed.
1. The second notice complied with the statute and regulations. The relevant language of 7 U.S.C. § 2020(e)(10) -- which does not itself mandate any notice at all, but merely assumes that a hearing request by a household aggrieved by a state agency's action will be preceded by "individual notice of agency action" -- cannot be fairly construed as a command to give notice of a general change in the law. The legislative history does not suggest that Congress intended to eliminate the distinction between requiring advance notice of an "adverse action" based on the particular facts of an individual case and the absence of any requirement of individual notice of a "mass change" in the law. And the notice in question complied with the applicable regulation requiring individual
notices of a "mass change," but not an adverse action notice when benefits are reduced or terminated as a result of a "mass change." Pp. 472 U. S. 123-127.
2. The second notice did not violate the Due Process Clause. Pp. 472 U. S. 127-131.
(a) Even if it is assumed that the mass change increased the risk of erroneous reductions in benefits, that assumption does not support the claim that the notice was inadequate. The notice plainly informed each household of the opportunity to request a fair hearing and the right to have its benefit level frozen if a hearing was requested. Pp. 472 U. S. 127-128.
(b) This case does not concern the procedural fairness of individual eligibility determinations, but rather involves a legislatively mandated substantive change in the scope of the entire food stamp program. The procedural component of the Due Process Clause does not impose a constitutional limitation on Congress' power to make such a change. A welfare recipient is not deprived of due process when Congress adjusts benefit levels; the legislative process provides all the process that is due. Here, the participants in the food stamp program had no greater right to advance notice of the change in the law than did any other voters. Because the substantive reduction in the level of petitioners' benefits was the direct result of the statutory amendment, they have no basis for challenging the procedure that caused them to receive a different, less valuable property interest after the amendment became effective. As a matter of constitutional law, there can be no doubt concerning the sufficiency of the notice describing the effect of the amendment in general terms. Pp. 472 U. S. 128-131.
722 F.2d 933, reversed.
STEVENS, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, BLACKMUN, POWELL, REHNQUIST, and O'CONNOR, JJ., joined. BRENNAN, J., filed a dissenting opinion, in Part I of which MARSHALL, J., joined, post, p. 472 U. S. 132. MARSHALL, J., filed a dissenting opinion, post, p. 472 U. S. 157.