Robert Peer, Director, Etc. v. Nanette Griffeth
The Supreme Court declined to hear an appeal from a Ninth Circuit ruling that extended a prior decision requiring pre-termination welfare hearings to also cover people whose initial applications for benefits were denied.
Justice Rehnquist dissented from the denial, arguing the appeals court had significantly expanded existing law and that the question deserved full review, especially since a California appellate court had reached the opposite conclusion.
How it got here: A federal district court ruled against the applicants; the Ninth Circuit reversed in their favor; the state sought Supreme Court review, which was denied.
The Case in Depth
What happened
People applying for county-run general relief welfare benefits in California had their applications denied without a hearing. They sued, arguing that the same kind of hearing the Supreme Court had earlier required before cutting off existing welfare recipients should also apply to people newly applying for benefits.
The question before the Court
Should someone denied welfare benefits for failing initial eligibility rules get a hearing first, the way benefit recipients do before termination?
Why it matters
County welfare agencies in the Ninth Circuit may now need to provide hearings before denying general relief applications, not just before cutting off existing benefits, changing how local welfare offices process new applicants and adding procedural steps agencies must follow.
What changes now
Because certiorari was denied, the Ninth Circuit's decision extending pre-denial hearing rights to welfare applicants remains in effect within that circuit. The Supreme Court did not resolve the underlying disagreement with the California state courts, so the same question could resurface in a future case seeking full review.
What this does not decide
A denial of certiorari is not a ruling on the merits and sets no nationwide precedent. The Supreme Court did not decide whether applicants have a protected property interest in general relief benefits; it simply declined to review the Ninth Circuit's decision on that question.
Concurrences and dissents
How the Justices voted
Dissent (1). Justice Rehnquist (author).
Dissent — Justice Rehnquist
“refused to find general relief to be a protected property interest.”Describing how a California state court had ruled on whether applicants have a protected interest in benefits.
Justice Rehnquist argued the Ninth Circuit significantly expanded the Court's earlier ruling requiring hearings before terminating welfare benefits by applying it to people whose initial applications were denied. He noted a California state appellate court had reached the opposite conclusion, finding no protected property interest in general relief. Given this conflict and the significance of the expansion, he believed the case deserved full Supreme Court review rather than a denial of certiorari. Read the full dissent →
How the Court got there
The legal reasoning, step by step
- This is an order denying certiorari, so the full Court did not rule on the merits; the excerpted reasoning below comes only from Justice Rehnquist's dissent from that denial.
- Rehnquist noted that a prior Supreme Court case had required a hearing before terminating existing welfare recipients' benefits, and that the appeals court below extended that rule to cover people whose initial applications were denied, which he viewed as a significant expansion.
- He observed that whether such an extension is justified turns on whether state law creates a protected 'property interest' in the benefit — a threshold question under the Due Process Clause that determines whether any hearing is required at all.
- He pointed out that a California state appellate court had already decided the opposite: that applicants have no protected property interest in general relief, creating a conflict the dissent thought worth resolving.
- Because of this conflict and the significance of expanding the hearing requirement beyond existing recipients to new applicants, Rehnquist concluded the question merited full briefing and argument rather than being left undisturbed by a denial of review.
Doctrinal impact
Cases affected by this decision
Limits Goldberg v. Kelly (397 U. S. 254)
The dissent argued the lower court expanded this ruling's hearing requirement beyond what it originally covered.