New York Law Review

Matter of Davis v. Smith, 43 N.Y.2d 480 (1978): Home Relief Eligibility for SSI Recipients

Published by

The New York Law Review

in

43 N.Y.2d 480 (1978)

New York Social Services Law § 158(a), which barred Supplemental Security Income (SSI) recipients from obtaining home relief, is unconstitutional.

Summary

This case addresses whether an individual receiving benefits as an “essential person” under the SSI program could be denied home relief benefits under New York Social Services Law § 158(a). The Court of Appeals reversed the Appellate Division’s order, holding that, in light of the court’s decision in Matter of Lee v. Smith, § 158(a) was unconstitutional insofar as it barred SSI recipients from obtaining home relief. The court found it unnecessary to determine whether the petitioner was correctly classified as an SSI recipient because of his “essential person” status.

Facts

The petitioner, Davis, sought home relief benefits. The local social services agency denied the application, asserting that Davis was an SSI recipient due to his status as an “essential person” under the SSI program. At the time, New York Social Services Law § 158(a) prohibited SSI recipients from receiving home relief.

Procedural History

The case reached the New York Court of Appeals after a decision by the Appellate Division. The Court of Appeals reversed the Appellate Division’s order, effectively granting Davis’s petition for home relief.

Issue(s)

Whether New York Social Services Law § 158(a) is constitutional insofar as it bars SSI recipients from obtaining home relief.

Holding

Yes, because the Court in Matter of Lee v. Smith held that subdivision (a) of section 158 of the Social Services Law is unconstitutional insofar as it bars SSI recipients from obtaining home relief.

Court’s Reasoning

The Court of Appeals based its decision entirely on its companion ruling in Matter of Lee v. Smith. In Lee, the court determined that barring SSI recipients from home relief was unconstitutional. Given this holding, the court found it unnecessary to delve into the specifics of Davis’s classification as an SSI recipient through his “essential person” status. The court summarily reversed the lower court’s decision. Judge Jones dissented, referencing his dissent in Matter of Lee v. Smith, and stating that the commissioner’s prospective modification of interpretation does not invalidate the prior determination made during the case’s brief period.

More ARTICLES