Supreme Court of the United States
Atkins v. Parker
June 4, 1985472 U.S. 115
Summary
The Court held that Massachusetts lawfully notified food-stamp recipients of a legislatively mandated reduction in the earned-income deduction. The notice satisfied the governing statute and regulation because it individually informed recipients of the general program change and explained their hearing rights, and due process did not require individualized calculations before implementing the legislative change. Justice Brennan, joined in part by Justice Marshall, dissented, arguing that the regulation and Due Process Clause required individualized information sufficient to identify possible administrative errors.
Holding
- Statutory notice requirement. The Food Stamp Act did not require individualized notice of the precise effect of a general legislative change in food-stamp eligibility or benefit levels. Its reference to individual notice presupposed notice sufficient to permit a household to request a fair hearing concerning agency action, but did not require individual hearings or individualized computations for every household affected by a mass change.
- Regulatory notice requirement. The supplemental notice complied with the applicable mass-change regulation because Massachusetts sent a separate notice to each household and informed recipients of the legislatively mandated change. The regulation did not require the notice to state each household's old and new benefit amounts or provide individualized calculations.
- Procedural due process. The Due Process Clause did not require Massachusetts to provide advance individualized notice of each recipient's new benefit amount before implementing the statutory reduction. The notice adequately protected recipients because it explained the general change, informed them of the right to request a fair hearing, and allowed benefits to continue at the prior level pending resolution of a qualifying challenge.
Docket 83-1660
Cited authorities
- 7 C.F.R. §§ 271.1
- 7 C.F.R. §§ 273.15
- 7 U.S.C. §§ 2011-2029
- 7 C.F.R. § 273.13(a)(1)
- 43 FR 18896
- 7 U.S.C. § 2020
- 7 C.F.R. § 273.12
- 78 Stat. 703
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