46 N.Y.2d 823 (1978)

Public assistance for funeral expenses is limited to the amount fixed by the appropriate public welfare official or local appropriating body, and reimbursement can be denied if the funeral arrangements exceed that amount.

Summary

Ben Mendelsohn sought public assistance from the Westchester County Department of Social Services to cover the funeral expenses of his wife. The Department had a regulation limiting reimbursement for funerals to $650. Mendelsohn arranged for a funeral costing $1,312.42 and was denied reimbursement. The Court of Appeals reversed the lower court’s decision, holding that the denial of reimbursement was proper because the funeral expenses exceeded the maximum amount fixed by the Department’s regulation and the governing statute. The court emphasized the clear statutory language and the implementing regulation.

Facts

Ben Mendelsohn’s wife passed away, and he arranged for her funeral. The funeral expenses amounted to $1,312.42. Mendelsohn was aware that the Westchester County Department of Social Services had a regulation limiting funeral expense reimbursement to a maximum of $650. The regulation stated that the department would pay up to $650 for a complete funeral of adult persons who die in Westchester County under specific conditions, including that the total funeral bill cannot exceed $650.

Procedural History

Mendelsohn’s request for public assistance to cover his wife’s funeral expenses was denied by the Westchester County Department of Social Services. He challenged the denial, and the case made its way through the New York court system. The Court of Appeals ultimately reversed the lower court’s order and reinstated the determination of the State Commissioner, upholding the denial of reimbursement.

Issue(s)

Whether the Department of Social Services properly denied reimbursement for funeral expenses when the funeral arrangements exceeded the maximum amount fixed by the Department’s regulation.

Holding

Yes, because Subdivision 3 of section 141 of the Social Services Law and the implementing regulation of the Westchester County Department of Social Services clearly limit the amount of reimbursement for funeral expenses, and the petitioner knowingly exceeded that limit.

Court’s Reasoning

The court based its decision on the plain language of Subdivision 3 of section 141 of the Social Services Law, which allows public welfare officials to pay for funeral expenses within specified limits. The Westchester County Department of Social Services had implemented a regulation setting the maximum reimbursable amount at $650. The court highlighted the specific language of the regulation, emphasizing that the “total funeral bill cannot exceed $650.” The court found that Mendelsohn’s awareness of this regulation, coupled with his decision to arrange a funeral costing more than twice the maximum reimbursable amount, justified the Department’s denial of reimbursement. The court stated that the denial was proper “in the face of clear statutory language and an equally clear implementing regulation.” There were no dissenting or concurring opinions noted in the memorandum decision.