Khrapunskiy v. Doar, 12 N.Y.3d 43 (2009)
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Article XVII of the New York State Constitution does not compel the state to provide Safety Net Assistance (SNA) at the same level as Supplemental Security Income/Additional State Payments (SSI/ASP) to legal immigrants who become ineligible for SSI/ASP due to federal law changes.
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Summary
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This case addresses whether New York State must provide the same level of public assistance to legal immigrants who are aged, blind, or disabled but ineligible for federal SSI/ASP benefits, as it does to citizens receiving SSI/ASP. The Court of Appeals held that the state is not obligated to provide the same level of benefits under Article XVII of the New York Constitution or the Equal Protection Clause. The decision emphasizes the legislature’s prerogative to determine who is needy and how to allocate public funds, and distinguishes prior cases where state-funded programs discriminated based on alienage.
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Facts
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The plaintiffs were legal resident aliens in New York who were aged, blind, or disabled. They became ineligible for SSI/ASP benefits because they did not become citizens within the timeframe mandated by the federal Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA). As a result, they received public assistance through the state’s Safety Net Assistance (SNA) program, which provided significantly lower benefits than SSI/ASP.
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Procedural History
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The plaintiffs sued the Commissioner of the New York State Office of Temporary and Disability Assistance (OTDA), arguing that they were entitled to the same level of benefits as SSI/ASP recipients. Supreme Court granted class certification and summary judgment to the plaintiffs, holding that the state’s failure to provide equal assistance violated Article XVII of the New York Constitution and the Equal Protection Clauses of the federal and state constitutions. The Appellate Division affirmed. The Court of Appeals reversed.
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Issue(s)
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1. Whether Article XVII, § 1 of the New York Constitution requires the state to provide SNA benefits at the same standard of need as SSI/ASP, as defined in Social Services Law § 209(2), to legal immigrants ineligible for SSI/ASP.
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2. Whether the state’s provision of lower SNA benefits to legal immigrants, compared to SSI/ASP benefits for citizens, violates the Equal Protection Clauses of the Fourteenth Amendment to the United States Constitution and Article I, § 11 of the New York Constitution.
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Holding
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1. No, because Article XVII, § 1 grants the legislature discretion to determine how to aid the needy, and Social Services Law § 209(2) sets a standard of need for SSI recipients, not a general standard for all aged, blind, or disabled individuals.
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2. No, because the state did not create a classification drawn along suspect lines, as the alienage restriction was mandated by federal law (PRWORA), and thus there is no equal protection violation.
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Court’s Reasoning
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The Court reasoned that Article XVII, § 1 of the New York Constitution requires the state to provide for the needy but does not mandate a specific level of aid or require public assistance to be granted on an individual basis in every instance. Citing Matter of Bernstein v Toia, the court emphasized that the Legislature has the prerogative to determine who is needy and allocate public funds. The court distinguished ASP as a supplement to the federal SSI program, not a stand-alone program setting a