State v. Middleton
2012 ND 181
| N.D. | 2012Background
- Ennis, a self-employed individual, has received SNAP benefits since 2008 via Williams County; recertifications use prior year income minus allowable business expenses.
- In 2010 Ennis purchased a work truck for $5,238, paid in full, as a one-time business expense.
- For the 2011 recertification, the County computed anticipated 2011 self-employment income using Ennis’s 2010 income without deducting the 2010 truck cost.
- The ALJ recommended deducting the truck cost for 2011, but the Department amended findings denying further SNAP benefits.
- The district court reversed, reinstating the ALJ’s recommended findings; the Department appealed and Ennis cross-appealed on costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the truck purchaseCost should be deducted in calculating 2011 anticipated income. | Ennis/Ennis argues the 2010 truck expense is a one-time cost that should be deducted for 2011. | Department argues the one-time expense is not deductible for 2011 and should not affect 2011 eligibility. | Deduction not required; department’s interpretation upheld. |
| Whether the Department’s interpretation of 7 C.F.R. § 273.10 and § 273.11 is reasonable and entitled to deference. | District court reversal flawed; (Ennis) argues for a different interpretation that credits the 2010 expense. | Agency interpretation is reasonable and entitled to deference. | Agency interpretation deemed reasonable and entitled to deference. |
| Whether the district court properly applied the standard of review for administrative agency decisions. | Lower court should have deferred more to the agency’s regulatory interpretation. | Standard of review supports upholding the agency’s final order. | Agency decision affirmed; district court reversed. |
Key Cases Cited
- Kaspari v. Olson, 2011 ND 124 (2011 ND 124) (limited review of agency decisions; deference to agency conclusions)
- Simons v. State, 2011 ND 190 (2011 ND 190) (limited review and deference; agency findings reviewed for reasonableness)
- Meyer v. Lyng, 859 F.2d 62 (8th Cir. 1988) (use of anticipated income where substantial change in circumstances exists)