Hagans v. Lavine (1974)

New York regulation permitting the State to recoup prior unscheduled payments for rent from subsequent grants under the AFDC program violates the Equal Protection Clause of the Fourteenth Amendment.

Citation: 415 U.S. 528 (1974)
Date decided: Mar 25, 1974
Longer case name: Cynthia HAGANS et al., Petitioners, v. Abe LAVINE, Commissioner of New York State Department of Social Services, et al.
Law type: Civil
Jurisdiction level:Federal
State of origin: New York
Topic(s):Equal protection and Public assistance
Lists:Important cases
Attorneys:Carl Jay Nathanson, Hempstead, N.Y., for petitioners. (Nassau County Law Services Committee)
Others involved:
More info:

Case Importance

From Wikipedia: “Black held that while the state court was not required by the federal constitution to provide appellate courts or a right to appellate review, because the state did grant appellate review at all stages of the proceedings, the Due Process and Equal Protection Clauses protected the prisoners from invidious discriminations. The court held that destitute defendants must be afforded as adequate appellate review as defendants who had enough money to buy the transcripts. It was held that the due process and equal protection clauses of the Fourteenth Amendment were violated by the state’s denial of appellate review solely on account of a defendant’s inability to pay for a transcript.The court vacated and remanded the order from the state supreme court. The court held that petitioner prisoners had to be afforded as adequate appellate review as defendants with money to buy transcripts.”

Case Details

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)


Petitioners, recipients of public assistance under the federal-state Aid to Families with Dependent Children (AFDC) program, brought this action under 42 U.S.C. 1983 and 28 U.S.C. § 2201 challenging a New York regulation permitting the State to recoup prior unscheduled payments for rent from subsequent grants under the AFDC program, on the ground that the regulation violated the Equal Protection Clause of the Fourteenth Amendment and conflicted with the Social Security Act and implementing regulations of the Department of Health, Education, and Welfare (HEW). Injunctive and declaratory relief was sought and jurisdiction was invoked under 28 U.S.C. 1343(3) and (4). The District Court declared the recoupment regulation contrary to the Social Security Act and HEW regulations and enjoined its implementation or enforcement. The Court of Appeals reversed, holding that because petitioners had failed to present a substantial constitutional claim, the District Court lacked jurisdiction to entertain either the equal protection or the statutory claim. Held:

1. The District Court had jurisdiction under 28 U.S.C. 1343(3). Pp. 534—543.

(a) Section 1343(3) conferred jurisdiction to entertain the constitutional claim if it was of sufficient substance to support federal jurisdiction, in which case, the District Court could hear as a matter of pendent jurisdiction the claim of conflict between federal and state law, without determining that the latter claim in its own right was encompassed within § 1343. P. 536.

(b) Within the accepted substantiality doctrine, petitioners’ complaint alleged a constitutional claim sufficient to confer jurisdiction on the District Court to pass on the controversy, since (1) the complaint alleged a deprivation, under color of state law, of constitutional rights within the meaning of § 1343(3) and s 1983; (2) the equal protection issue was neither frivolous nor so insubstantial as to be beyond the District Court’s jurisdiction, and the challenged regulation was not so clearly rational as to require no meaningful consideration; and (3) the cause of action alleged was not so patently without merit as to justify a dismissal for want of jurisdiction, Bell v. Hood, 327 U.S. 678, 66 S.Ct. 773, 90 L.Ed. 939, whatever may be the ultimate resolution of the federal issues on the merits. Pp. 536—543.

2. Given a constitutional question over which the District Court had jurisdiction, it also had jurisdiction over the ‘statutory’ claim. The latter claim was to be decided first and could be decided by the single district judge, while the constitutional claim could be adjudicated only by a three-judge court and only if the statutory claim was previously rejected. Pp. 543—545.

3. State law claims pendent to federal constitutional claims conferring jurisdiction on a district court generally are not to be dismissed. Given advantages of economy and convenience and no unfairness to litigants, they are to be adjudicated, particularly where they may be dispositive and their decision would avoid adjudication of federal constitutional questions. There are special reasons to adjudicate the pendent claim where, as here, the claim, although called ‘statutory,’ is in reality a constitutional claim arising under the Supremacy Clause, since ‘federal courts are particularly appropriate bodies for the application of pre-emption principles.’ Mine Workers v. Gibbs, 383 U.S. 715, 729, 86 S.Ct. 1130, 1140—1141, 16 L.Ed.2d 218. Pp. 545 550.

471 F.2d 347, reversed and remanded

Last modified: 2022-12-27 12:50
Case internal grade: A | Case internal status: OK |
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