Matter of Gonzalez v. Grinker, 76 N.Y.2d 354 (1990)

A needy person residing in a shelter that provides meals is not automatically entitled to a food allowance under Social Services Law § 131-a(2)(b); they must demonstrate that their inability to prepare meals at home results in an additional cost for food.

Summary

Gonzalez, a resident of a public shelter receiving a monthly Home Relief grant, sought a food allowance under Social Services Law § 131-a(2)(b), arguing he could not prepare meals at home. The Commissioner denied his request because the shelter provided meals. The lower courts reversed, relying on Jiggetts v. Grinker. The Court of Appeals reversed, holding that the statute requires a showing of “additional cost” for meals, which Gonzalez could not demonstrate as the shelter provided them. The court emphasized that the Commissioner’s interpretation of the statute was rational and should be upheld.

Facts

Gonzalez resided at the Ward’s Island Shelter, receiving a $45 monthly Home Relief grant in exchange for working 20 hours per week. The shelter regulations mandated the provision of three balanced and nutritious meals daily to residents (18 NYCRR 491.9[a]). Despite this, Gonzalez applied for a food allowance under Social Services Law § 131-a(2)(b) because he claimed he was unable to prepare meals at home. The Commissioner initially denied the request, but awarded retroactive relief for meals missed due to his Public Works Program duties.

Procedural History

Gonzalez initiated a CPLR article 78 proceeding, arguing the Commissioner’s decision was arbitrary. Supreme Court granted the petition, and the Appellate Division affirmed, citing Jiggetts v. Grinker. The Court of Appeals then reviewed the case after the Commissioner appealed the Appellate Division’s order.

Issue(s)

Whether a needy person residing in a shelter providing meals is automatically entitled to a food allowance under Social Services Law § 131-a(2)(b), or whether they must demonstrate that their inability to prepare meals results in an “additional cost” for food.

Holding

No, because Social Services Law § 131-a(2)(b) requires a showing of “additional cost” for meals, which Gonzalez could not demonstrate as the shelter provided meals at no cost to him. The Commissioner’s determination was a rational interpretation of the statute.

Court’s Reasoning

The Court of Appeals reasoned that Social Services Law § 131-a(2)(b) specifically refers to “amounts for additional cost of meals for persons who are unable to prepare meals at home.” The court emphasized that applicants must demonstrate that their inability to prepare meals results in a need to incur the “additional cost” of eating out. Because the shelter provided meals to Gonzalez at no cost, he could not demonstrate that he necessarily incurred any “additional cost.” The court distinguished this case from Jiggetts v. Grinker, noting that Jiggetts addressed the adequacy of shelter allowances, whereas this case concerns the specific requirement of showing “additional cost” for food allowances.

The court also noted that the Commissioner could reasonably conclude that the shelter was Gonzalez’s “home” and that he did not fall within the category of persons “unable to prepare meals at home,” likening his situation to someone living at home whose meals are prepared by another resident. The court stated that because the Commissioner’s determination rested on a rational interpretation of the statute, it should be accepted by the court, citing Matter of Lumpkin v Department of Social Servs., 45 NY2d 351, 356.

Furthermore, the court clarified the statute’s language, stating that “the Appellate Division’s conclusion that the word ‘shall’ in the statute mandates payment of the allowance to ‘supplement’ Home Relief payments, notwithstanding the availability of meals to petitioner at the shelter, fails to give meaning to the language of the statute directing payment only when the applicant incurs ‘additional cost’ for meals.”