Barry Ex Rel. Barry v. Lyon
834 F.3d 706
6th Cir.2016Background
- Plaintiffs (individual SNAP recipients and an advocacy organization) sued Michigan, challenging a state law and automated policy that automatically disqualify SNAP benefits when a household member appears in LEIN as subject to an outstanding felony warrant.
- Michigan’s system (the “fugitive felon interface”) matches benefit recipients to outstanding felony-warrant entries and automatically closes cases, sending a generic “criminal justice disqualification” notice directing recipients to contact law enforcement.
- Named plaintiffs reported repeated, sometimes prolonged denials or terminations of benefits, including due to mistaken or unclear warrant records and practical obstacles to resolving the warrant entries.
- Plaintiffs sought declaratory and injunctive relief, arguing the state policy violates SNAP (7 U.S.C. §§ 2011–2036c) and the Due Process Clause by: (1) adding an automatic warrant-based disqualification beyond the federal “fleeing felon” standard, and (2) providing inadequate notices and hearing procedures.
- The district court granted class certification, entered summary judgment for plaintiffs, enjoined automatic disqualifications based solely on outstanding warrants, and found the notice procedure violated due process; Michigan appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing / Mootness | Plaintiffs suffered concrete injuries from benefit terminations and face repetition; claims not moot. | State argued some plaintiffs lacked standing or became moot once benefits were reinstated or circumstances changed. | Affirmed: plaintiffs had standing at suit commencement; issues capable of repetition and not moot for key plaintiffs. |
| Private right of action under SNAP | SNAP provisions (7 U.S.C. §§ 2014(a), 2020(e)(10)) create enforceable individual rights amenable to § 1983 relief. | State argued SNAP/Supremacy Clause does not create a private right to sue the state. | Affirmed: statutory language and due‑process/hearing provisions create rights enforceable under § 1983. |
| Substantive disqualification standard | Michigan’s automatic warrant-based disqualification exceeds federal SNAP limits; federal law requires intent/active flight and law‑enforcement pursuit. | Michigan argued its statute and automated matching reasonably implement disqualification. | Affirmed: Michigan law/policy invalid—outstanding warrant alone is insufficient; must meet federal “fleeing” and “actively seeking” criteria. |
| Notice and hearing procedures / Due Process | Notices lack specific, individualized reasons (which warrant, charge, issuing agency) and fail to explain steps to reinstate benefits or hearing implications. | State contended the generic notice plus referral to MDHHS or law enforcement sufficed. | Affirmed: notices constitutionally inadequate and violated SNAP hearing/notice requirements; reference-only or referral insufficient. |
Key Cases Cited
- Blessing v. Freestone, 520 U.S. 329 (1997) (framework for identifying statute-created rights enforceable under § 1983)
- Gonzaga Univ. v. Doe, 536 U.S. 273 (2002) (private right analysis and presumption of § 1983 enforceability once a statute confers an individual right)
- Gean v. Hattaway, 330 F.3d 758 (6th Cir. 2003) (state-plan hearing provision creates enforceable right; Medicaid analogy)
- Fowlkes v. Adamec, 432 F.3d 90 (2d Cir. 2005) (outstanding warrant alone insufficient to establish fleeing-for-purposes-of-benefit-disqualification)
- Rosen v. Goetz, 410 F.3d 919 (6th Cir. 2005) (termination-notice sufficiency where follow-up letter supplied omitted details)