People v. Pickett, 19 N.Y.2d 170 (1967)
A conviction under Section 145 of the Social Welfare Law for a “wilful act designed to interfere with the proper administration of public assistance” requires proof of fraudulent intent, not simply a refusal to accept employment.
Summary
Pickett, a recipient of Temporary Aid to Dependent Children, was convicted of violating Section 145 of the Social Welfare Law after refusing a job referral. The New York Court of Appeals reversed his conviction, holding that Section 145 requires proof of fraudulent intent to obtain undeserved welfare payments. The court reasoned that the statute’s language, legislative history, and consistent administrative interpretation indicated that it was intended to penalize fraudulent acts, not simply refusals to accept employment. Interpreting the statute otherwise could lead to constitutional issues of vagueness and involuntary servitude.
Facts
Pickett was unemployed and receiving Temporary Aid to Dependent Children. The New York State Employment Service referred him to a landscaping job paying $1.50 an hour, above the minimum wage. Pickett refused the job, stating it “wasn’t enough money” and that he wanted to look for work on his own. He asked to postpone the referral to investigate a possible construction job. The Welfare Department, upon learning of this, terminated his welfare assistance, though payments to his wife and children were later resumed. Pickett was then criminally charged with violating Section 145 of the Social Welfare Law.
Procedural History
The City Court of Niagara Falls found Pickett guilty of violating Section 145 of the Social Welfare Law and sentenced him to 30 days in jail. The Niagara County Court affirmed the judgment of conviction. Pickett then appealed to the New York Court of Appeals.
Issue(s)
Whether a conviction under Section 145 of the Social Welfare Law for committing “any wilful act designed to interfere with the proper administration of public assistance and care” requires proof of fraudulent intent, or whether a simple refusal to accept a job referral is sufficient.
Holding
No, because the Legislature meant to provide penal sanctions only for acts motivated by fraudulent intent in seeking welfare benefits.
Court’s Reasoning
The court analyzed the legislative history of Section 145, noting that the language prohibiting a “wilful act designed to interfere with the proper administration of public assistance” originated in a section titled “Penalty for fraud; false representation and false swearing.” The court found no indication that the Legislature intended to effect a substantive change when it later shortened the title to simply “Penalties”. The court also emphasized the consistent interpretation of Section 145 by public officials charged with administering the welfare law, who only discussed criminal prosecutions under Section 145 in connection with fraud. Research also revealed that almost all prosecutions under Section 145 involved some element of fraud. The court stated, “Although the statutory language of section 145 is exceedingly broad, we believe that the Legislature meant to provide penal sanctions only for acts motivated by fraudulent intent.” The court also invoked the principle that statutes should be construed to avoid constitutional doubts. Without a requirement of fraudulent intent, Section 145 might be unconstitutionally vague or sanction involuntary servitude. The court quoted Matter of New York Post Corp. v. Leibowitz, stating that a statute “‘should be construed when possible in a manner which would remove doubt of its constitutionality.’” Judge Van Voorhis concurred in the result, finding Section 145 ambiguous and thus an insufficient foundation for a criminal charge.