University of Michigan Law School
Civil Rights Litigation Clearinghouse
new search
page permalink
Case Name Reynolds v. Giuliani PB-NY-0003
Docket / Court 1:98-cv-8877 ( S.D.N.Y. )
State/Territory New York
Case Type(s) Public Benefits / Government Services
Attorney Organization Legal Services/Legal Aid
Case Summary
New York City implemented an overhaul to its welfare system in order to meet federal and state welfare requirements, which were revised in the mid-1990s. Under the city’s program, “income support centers” (locations where public assistance benefits were applied for and distributed, sometimes ... read more >
New York City implemented an overhaul to its welfare system in order to meet federal and state welfare requirements, which were revised in the mid-1990s. Under the city’s program, “income support centers” (locations where public assistance benefits were applied for and distributed, sometimes during the initial visit by an applicant) were to be converted to “job centers.” These job centers put greater emphasis on making sure those receiving public assistance obtained employment from the private sector while doing so and added bureaucratic layers to the application process for public assistance compared to income support centers. Over half of the city’s income support centers had been converted to job centers at the time the suit was filed.

The plaintiffs each claimed to be qualified welfare beneficiaries who had been improperly denied assistance by one of the job centers in violation of the Fourteenth Amendment's Due Process clause, the city’s obligations under 7 U.S.C. §2020 (the Supplemental Nutritional Assistance Program—then referred to as Food Stamps), and 42 U.S.C. §1396 (Medicaid). The plaintiffs also alleged state law violations. They sought class certification for all similarly situated New York City residents, as well as declaratory and injunctive relief. The case was filed in the U.S. District Court for the Southern District of New York on December 16, 1998, with Judge William H. Pauley presiding.

The plaintiffs sought a temporary restraining order (1) enjoining the city from converting further income support centers into job centers; and (2) directing the city to expeditiously process the applications of the named plaintiffs. The court entered a temporary restraining order on the same day directing the city to provide emergency food stamps and cash assistance to the named plaintiffs.

The court granted a preliminary injunction to the plaintiffs on January 21, 1999. Finding the plaintiffs and others like them would suffer irreparable harm without intervention and that the evidence showed the conversion of income support centers to job centers was done with insufficient self-study and a statistical drop in the number of successful applicants for emergency assistance despite legal obligations, the court ordered the city to (1) allow applicants for public assistance to apply for benefits the first day they visit a job center, (2) cease conversion of income support centers to job centers without a formal hearing, (3) make eligibility requirements for food stamps and Medicaid separate from the eligibility determination from cash assistance, (4) send applicants timely notice of the city’s decision on whether they qualify for benefits, and (5) form a corrective plan for achieving its policy goals while also meeting the needs of public assistance applicants.

The city submitted a corrective action plan and requested modification to the preliminary injunction in March of 1999. On May 24, 1999, the preliminary injunction was modified to allow the closure of up to three more income support centers after an individualized hearing on the adequacy of city audit procedures. The court also approved of the city’s corrective action plan in the same order.

The city moved to vacate the preliminary injunction on December 10, 1999, after procuring more evidence surrounding the efficacy of the job centers in achieving their welfare obligations. Meanwhile, the State of New York moved to dismiss the complaint against them for failure to state a claim. Judge Pauley denied both motions and granted the plaintiff’s motion for class certification on July 21, 2000. The certified class consisted of "all New York City residents who have sought, are seeking, or will seek to apply for food stamps, Medicaid, and/or cash assistance at a Job Center."

Following a September 2000 audit of the city’s welfare distribution schematic, the court entered a permanent injunction in favor of the plaintiffs on December 30, 2004. The permanent injunction directed both the city and state to: (i) provide expedited food stamp service to eligible applications within 7 days; (ii) separately process applications for food stamps when the applications for cash assistance are denied or withdrawn; (iii) send notices to applicants confirming voluntary withdrawals for Medicaid in accord with 42 C.F.R. 435.913 and document such withdrawals pursuant to 7 C.F.R. 273.2(c)(6); and (iv) provide adequate and timely notice by correctly completing certain documentation. The injunction also required the state to supervise the city and make sure it met the obligations of the injunction.

On January 13, 2005, the plaintiffs moved for reconsideration of the part of the December order in which the court concluded that 8 N.Y.C.R.R. § 387.8(a)(2)(i)(a) did not confer a privately enforceable right of action and that plaintiffs’ claim under New York Social Services Law § 133 was barred by the doctrine of sovereign immunity. The court granted the motion and reversed its earlier decisions on these points on February 14, 2005. Final judgement was entered on December 14, 2005; at this time, the court also granted the plaintiffs a declaratory judgment that city officials had failed to provide the class with the obligations required of them by the relevant federal programs and further specified the parameters of the permanent injunction.

A stipulation and order resolving the issue of attorney fees was reached on January 31, 2007. The city agreed to pay the plaintiff class a total of $2,559,675.94 for the attorneys' fees incurred up through December 14, 2005. The state agreed to pay $639,918.98 for the plaintiffs' fees for the same period.

Both the state and the city appealed the permanent injunction to the U.S. Court of Appeals for the Second Circuit on January 12, 2006, but the city dropped its appeal shortly afterward. On October 31, 2007, the Second Circuit reversed the district court, ruling that the state did not have a non-delegable duty to administer the decentralized Medicaid and Food Stamp programs, the state’s efforts in supervising the city since the permanent injunction was issued were adequate, and the district court exceeded its authority by issuing a permanent injunction despite New York State’s affirmative supervisory steps it had taken to assure compliance. The Second Circuit ruling dismissed the claims against the state defendants, reversed the permanent injunction, and altered those parts of the December 14, 2005 judgement addressing the state government.

In a second stipulation and order from April 23, 2010, the City of New York agreed to pay a further $275,000.00 to the plaintiffs for attorney fees and costs from December 15, 2005 through December 14, 2008. A third stipulation and order from December 22, 2010, had the New York City Human Resources Administration (HRA), the agency in charge of implementing the changes at issue in this case, identify households which required but did not receive a separate food stamp determination between December 15, 2005 and November 30, 2006, as a result of an application at a job center in which a request for public assistance was denied, and restore those benefits.

A final stipulation and order was issued on July 22, 2011, in which the city agreed to pay $86,000.00 in attorneys' fees and costs sought to the plaintiffs for the period between December 15, 2008 and June 14, 2010. This was the most recent item on the docket; the case is now closed.

John Duffield - 07/22/2021


compress summary

- click to show/hide ALL -
Issues and Causes of Action
click to show/hide detail
Issues
Benefit Source
Food stamps
Medicaid
Temporary Assistance for Needy Families (TANF)
Constitutional Clause
Due Process
Due Process: Procedural Due Process
Content of Injunction
Auditing
Monitoring
Preliminary relief granted
Defendant-type
Jurisdiction-wide
General
Government Services (specify)
Public benefits (includes, e.g., in-state tuition, govt. jobs)
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
State law
Defendant(s) City of New York
New York City Human Resources Administration
New York State Department of Health
New York State Office of Temporary and Disability Assistance
Plaintiff Description All New York City residents who have sought, are seeking, or will seek to apply for food stamps, Medicaid, and/or cash assistance at a Job Center.
Indexed Lawyer Organizations Legal Services/Legal Aid
Class action status sought Yes
Class action status outcome Granted
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Preliminary injunction / Temp. restraining order
Declaratory Judgment
Attorneys fees
Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement Confession of Judgment
Order Duration 1999 - 2007
Filed 12/16/1998
Case Closing Year 2011
Case Ongoing No
Additional Resources
click to show/hide detail
  See this case at CourtListener.com (May provide additional documents and, for active cases, real-time alerts)
  Reforming Welfare after Welfare Reform -- Reynolds v. Giuliani
Date: Jul. 19, 2017
By: Alice Bers (Harvard Law School Law Student)
Citation: 36 Harv. C.R.-C.L. L. Rev. 571 (2001)
[ Detail ] [ PDF ] [ External Link ]

Court Docket(s)
S.D.N.Y.
07/22/2011
1:98−cv−08877
PB-NY-0003-9000.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
General Documents
S.D.N.Y.
01/07/1999
Memorandum and Order [Denying Motion to Videotape Proceedings] [ECF# 6] (1999 WL 9836)
PB-NY-0003-0001.pdf | WESTLAW | Detail
Source: Westlaw
S.D.N.Y.
01/21/1999
Memorandum and Order [Denying Defendants' Motion in Limine] [ECF# 9] (1999 WL 33027)
PB-NY-0003-0002.pdf | WESTLAW | Detail
Source: Westlaw
S.D.N.Y.
01/26/1999
Memorandum and Order [Granting Injunction in Part] [ECF# 10] (35 F.Supp.2d 331)
PB-NY-0003-0003.pdf | WESTLAW| LEXIS | Detail
Source: Westlaw
S.D.N.Y.
05/24/1999
Memorandum and Order [Modifying Injunction] [ECF# 66] (43 F.Supp.2d 492)
PB-NY-0003-0004.pdf | WESTLAW| LEXIS | Detail
Source: Westlaw
S.D.N.Y.
07/21/2000
Memorandum and Order [Granting Motion for Class Certification] [ECF# 125] (118 F.Supp.2d 352)
PB-NY-0003-0005.pdf | WESTLAW| LEXIS | Detail
Source: Westlaw
S.D.N.Y.
02/14/2005
Amended Memorandum and Opinion [Regarding a Permanent Injunction] [ECF# 205] (2005 WL 342106)
PB-NY-0003-0007.pdf | WESTLAW | Detail
Source: Westlaw
S.D.N.Y.
02/14/2005
Order [Withdrawing Memorandum and Opinion] [ECF# 206] (2005 WL 351729)
PB-NY-0003-0006.pdf | WESTLAW | Detail
Source: Westlaw
S.D.N.Y.
12/14/2005
Judgment [ECF# 216] (2005 WL 3428213)
PB-NY-0003-0008.pdf | WESTLAW | Detail
Source: Westlaw
U.S. Court of Appeals
10/20/2006
Stipulation for a Partial Withdrawal of Appeal [Ct. of App. ECF# 251]
PB-NY-0003-0010.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
01/31/2007
Stipulation and Order [ECF# 255]
PB-NY-0003-0011.pdf | Detail
Source: Westlaw
U.S. Court of Appeals
10/31/2007
Opinion [Reversing Injunction] (506 F.3d 183)
PB-NY-0003-0009.pdf | WESTLAW| LEXIS | Detail
Source: Westlaw
S.D.N.Y.
04/23/2010
Stipulation and Order [ECF# 258]
PB-NY-0003-0012.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
12/22/2010
Stipulation [ECF# 260]
PB-NY-0003-0013.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D.N.Y.
07/22/2011
Stipulation and Order [ECF# 261]
PB-NY-0003-0014.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Cardamone, Richard J. (Second Circuit) show/hide docs
PB-NY-0003-0009
Pauley, William H. III (S.D.N.Y.) show/hide docs
PB-NY-0003-0001 | PB-NY-0003-0002 | PB-NY-0003-0003 | PB-NY-0003-0004 | PB-NY-0003-0005 | PB-NY-0003-0006 | PB-NY-0003-0007 | PB-NY-0003-0008 | PB-NY-0003-0011 | PB-NY-0003-0012 | PB-NY-0003-0013 | PB-NY-0003-0014 | PB-NY-0003-9000
Straub, Chester J. (Second Circuit) show/hide docs
PB-NY-0003-0009
Wallace, William James (N.D.N.Y., 2d (1869), Second Circuit) show/hide docs
PB-NY-0003-0009
Plaintiff's Lawyers Banks, Steven (New York) show/hide docs
PB-NY-0003-0012 | PB-NY-0003-0014
Callagy, Anne (New York) show/hide docs
PB-NY-0003-9000
Carden, Constance P. (New York) show/hide docs
PB-NY-0003-9000
Cohan, Marc (New York) show/hide docs
PB-NY-0003-0011 | PB-NY-0003-0012 | PB-NY-0003-0014 | PB-NY-0003-9000
Colon, Esperanza (New York) show/hide docs
PB-NY-0003-9000
Gold, Joshua (New York) show/hide docs
PB-NY-0003-9000
Goldfein, Joshua E. (New York) show/hide docs
PB-NY-0003-9000
Holder, Adriene L. (New York) show/hide docs
PB-NY-0003-9000
Jeffrey, Randall S. (New York) show/hide docs
PB-NY-0003-0012 | PB-NY-0003-0014 | PB-NY-0003-9000
Kelleher, Kathleen M. (New York) show/hide docs
PB-NY-0003-0012 | PB-NY-0003-0014
Lamb, Christopher D. (New York) show/hide docs
PB-NY-0003-9000
Lee, Hwan-Hui Helen (New York) show/hide docs
PB-NY-0003-9000
Parkin, Jason (New York) show/hide docs
PB-NY-0003-0012
Rosenberg, Scott Alan (New York) show/hide docs
PB-NY-0003-0012 | PB-NY-0003-0014 | PB-NY-0003-9000
Rosenfeld, Kenneth (New York) show/hide docs
PB-NY-0003-0012 | PB-NY-0003-9000
Scharf, Rebecca L. (New York) show/hide docs
PB-NY-0003-9000
Schulman, Yisroel (New York) show/hide docs
PB-NY-0003-9000
Tasheff, Petra T. (New York) show/hide docs
PB-NY-0003-0012 | PB-NY-0003-0014
Werner, Miriam (New York) show/hide docs
PB-NY-0003-0012
Zentner, Camille (New York) show/hide docs
PB-NY-0003-0014
Defendant's Lawyers Cardozo, Michael A. (New York) show/hide docs
PB-NY-0003-0011 | PB-NY-0003-0012 | PB-NY-0003-0014
Cuomo, Andrew M. (New York) show/hide docs
PB-NY-0003-0011
Hershler, James M. (New York) show/hide docs
PB-NY-0003-0011
Pines, Jonathan (New York) show/hide docs
PB-NY-0003-0011 | PB-NY-0003-0012 | PB-NY-0003-0014

- click to show/hide ALL -

new search
page permalink

- top of page -