Kelly v. Bane
This case involves an appeal concerning an amendment to the 'Emergency Home Relief' (EHR) program regulation, 18 NYCRR 370.3 (b) (2), which set an income eligibility cap at 125% of the Federal poverty guidelines. Plaintiffs, low-income families and individuals facing eviction, challenged the amendment's validity and the denial of their applications. While the Supreme Court declared the amendment invalid, the Appellate Division modified this, ruling that the amendment itself was not irrational. However, the Appellate Division found the New York State Department of Social Services' (DSS) interpretation and application of the income test—using prospective income rather than income at the time of the emergency—to be arbitrary and capricious. The court affirmed the remand of the cases, directing re-evaluation of eligibility based on a reasonable computation of income during the emergency period.