Lavine v. Milne, 42 N.Y.2d 64 (1977)
A denial of welfare benefits is not arbitrary or capricious if based on a reasonable interpretation of existing regulations, even if the applicant argues that the denial frustrates a broader statutory objective.
Summary
The New York Court of Appeals reversed the Appellate Division’s order and dismissed the petition of Lavine, a welfare recipient seeking baby-sitting allowances while attending a four-year college program. Lavine, already receiving Aid to Families with Dependent Children, argued that the denial of baby-sitting funds was arbitrary. The court held that the Department of Social Services’ denial was not arbitrary because state regulations only authorized such allowances for recipients in two-year vocational programs, a criterion Lavine did not meet. The court reasoned that when drawing lines between eligible recipients, the department’s choice to distinguish between two-year vocational programs and four-year undergraduate programs was not unreasonable.
Facts
Lavine was a welfare recipient receiving Aid to Families with Dependent Children. She was a full-time student in the last two years of a four-year college program to obtain a teaching degree. She applied for an allowance to cover baby-sitting fees, which would enable her to attend classes. The State Department of Social Services denied her application.
Procedural History
Lavine petitioned the court after her application for baby-sitting allowances was denied. The lower court’s decision, and the Appellate Division’s order were not specified in the Court of Appeals decision. The New York Court of Appeals reversed the Appellate Division’s order and dismissed Lavine’s petition.
Issue(s)
- Whether the denial of baby-sitting allowances to a welfare recipient in a four-year college program was arbitrary or capricious when state regulations only authorized such allowances for recipients in two-year vocational programs.
Holding
- No, because the department’s decision to draw a line between two-year vocational programs and four-year undergraduate programs for eligibility was not unreasonable.
Court’s Reasoning
The court found that Lavine did not meet the criteria for baby-sitting allowances as defined by the State Department of Social Services regulations. The regulations specifically authorized allowances for recipients