Robert Peer, Director, Etc. v. Nanette Griffeth
Headline: Declining to review, the Court leaves a Ninth Circuit decision that extends hearing protections to welfare applicants in place, affecting denied applicants seeking state general relief and leaving questions unresolved nationally.
Holding: The Court refused to hear the appeal and denied review of the Ninth Circuit’s decision extending hearing protections to welfare applicants, leaving the lower-court ruling intact while Justice Rehnquist dissented.
- Leaves Ninth Circuit expansion of hearing rights available to local welfare applicants.
- Maintains uncertainty about hearing rights for welfare applicants in other states.
- Signals possible future Supreme Court review because Justices disagree.
Summary
Background
A county welfare director and state officials sought review of a Ninth Circuit decision that had applied pre-deprivation hearing protections to people denied initial welfare benefits. The dispute arose after denied applicants for San Diego County "General Relief" challenged the lack of a hearing when they failed to meet initial state requirements. A California appellate case (Zobriscky) had earlier held that such applicants were not entitled to a hearing or a protected property interest under state law.
Reasoning
The key question was whether people applying for state-mandated welfare must get a hearing under the Fourteenth Amendment before being denied benefits for failing initial eligibility rules. The full Court declined to hear the appeal and denied review, leaving the Ninth Circuit’s expansion of Goldberg v. Kelly in place. The district court had ruled against the applicants, and the materials show disagreement among lower courts and scholars about what counts as a protected property interest and what procedures are required.
Real world impact
Because the Court refused review, the Ninth Circuit outcome stands in that circuit, so some denied applicants may receive hearing protections while the broader question remains unsettled in other places. The ruling is not a final resolution on the merits for the whole country and could be revisited later. State-by-state differences and prior state appellate rulings mean applicants’ rights may vary by location.
Dissents or concurrances
Justice Rehnquist dissented from the denial, arguing that the extension of Goldberg’s hearing protections to denied applicants warrants full Court review because of its importance and conflicting state decisions.
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