Cindy Gregory v. Town of Pittsfield

Background

Cindy Gregory and her husband applied in Pittsfield, Maine, on April 13, 1982, for general assistance. The town manager denied the request, saying she quit her job and spent an AFDC check to free her husband from jail. The town failed to give the required written notice of reasons and of the right to an administrative hearing. Mrs. Gregory sought help again and filed for a hearing on April 23; the town denied assistance again and the local hearing authority later upheld the April 13 denial and refused to review the April 23 application.

Reasoning

The core question was whether people who apply for local general assistance have a protected property interest that triggers constitutional procedural safeguards and whether state remedies are adequate. The Maine Superior Court first found a due process violation and awarded benefits, later dismissing the federal claim. The Maine Supreme Judicial Court affirmed dismissal, explaining that state law requires a fresh showing of need for each grant so applicants have only an abstract expectancy, and alternatively held that postdeprivation hearings and judicial review satisfied due process under Parratt.

Real world impact

Because the Supreme Court denied review, those state-court conclusions remain in place: people seeking general assistance were left to state procedures rather than a federal constitutional remedy. The town eventually provided the denied aid nearly one year later, but the record shows the family alleged they were forced to leave their home and move because of the denial. The decision leaves open whether municipal policies that withhold required notice and hearings can be cured by later state remedies, and the question could affect other applicants and local benefit practices.

Dissents or concurrances

Justice O'Connor, joined by Justices Brennan and Marshall, dissented from the denial of review. She said the case raised important unresolved issues, criticized extending Parratt to a municipal policy that withholds required notice, and warned that state remedies might not fully compensate for delayed relief or barred tort claims.