Huber v. Ohio Dept. of Job & Family Servs.
2025 Ohio 987
Ohio Ct. App.2025Background
- John Huber, previously part of a two-person assistance group (AG) receiving SNAP benefits, reported a change in household when he married; his spouse’s employment increased household income.
- The Montgomery County Department of Job and Family Services (MCDJFS) requested documentation of the new spouse’s employment and income, which showed a significant increase.
- Based on the income information, MCDJFS determined that the household's gross and net incomes exceeded SNAP eligibility thresholds, resulting in a denial of benefits.
- Huber appealed, arguing issues related to self-employment income calculation and the alleged inclusion of an insurance payment, but these arguments were not properly raised below.
- Both the hearing officer and trial court upheld the denial, finding correct income calculations and insufficient verification of self-employment or insurance income relevance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Inclusion/averaging of self-employment income | Income should be averaged due to fluctuating self-employment; more deductions needed. | Argument waived; no verified self-employment income was included in calculation. | Argument waived; no self-employment income included. |
| Inclusion of insurance payment | Insurance payout was wrongly counted as income and elevated his AG’s totals. | Argument waived; no evidence insurance payment affected calculation. | Argument waived; no evidence insurance payment counted. |
| Eligibility thresholds for SNAP | AG should be eligible if income properly calculated with correct deductions. | AG’s income (gross/net) exceeded SNAP limits based on submitted documentation. | Gross/net income exceeded standards; ineligible accordingly. |
| Procedural compliance on appeal | Did not formally list assignments of error but sought appellate review. | Appellant failed to comply with App.R. 16; assignment of error requirements unmet. | Proceeded to merits, but found noncompliance and overruled. |
Key Cases Cited
- Pons v. State Med. Bd., 66 Ohio St.3d 619 (Ohio 1993) (sets standard of review in administrative appeals for abuse of discretion)
- AAAA Ents., Inc. v. River Place Community Urban Redevelopment Corp., 50 Ohio St.3d 157 (Ohio 1990) (defines the abuse of discretion standard)
- State ex rel. Zollner v. Indus. Comm. of Ohio, 66 Ohio St.3d 276 (Ohio 1993) (new legal arguments not raised below cannot be asserted for the first time on appeal)