Lavine v. Milne

Background

The case involves Milne and other people who applied for New York Home Relief, a low-level welfare program. New York law disqualifies anyone who voluntarily quits a job to get benefits for 75 days. A second sentence of the law and a matching regulation say that if someone applies within 75 days after quitting, the applicant will be "deemed" to have quit to qualify unless the applicant gives evidence to the contrary. The applicants sued, and a three-judge federal court found that sentence unconstitutional and enjoined its enforcement.

Reasoning

The Court reversed the three-judge court. It explained that applicants for Home Relief already must prove all elements of eligibility, and the disputed sentence simply makes clear that the applicant must show he did not quit to obtain benefits. The Court said this is a normal allocation of proof in civil administrative programs and is not the kind of unconstitutional presumption seen in criminal cases. The timing of administrative hearings and the possibility of initial incorrect denials did not make the rule unconstitutional, because applicants can appeal and, if successful, receive retroactive payments.

Real world impact

The decision lets New York—and similar welfare programs—require applicants to prove they did not quit work to get benefits, and it removes the injunction that had blocked that requirement as to Home Relief. Individuals who are denied will still have administrative appeals and may receive retroactive payments if they win on appeal. The ruling does not decide issues about other programs that were not before the Court.