Sutter v. Perales
The plaintiff, a home relief recipient, received a lump-sum Social Security settlement, leading to the discontinuation of her public assistance and a period of ineligibility under a Commissioner's regulation (18 NYCRR 352.29 [h]). She challenged the regulation's validity, arguing the Commissioner lacked rule-making authority for Home Relief recipients since the program is not federally funded and State amendatory legislation did not explicitly require such a rule. The court disagreed, holding that the 1981 amendatory legislation, read in its entirety and with legislative history, provided sufficient implicit authority for the Commissioner to enact the regulation. The court found that the legislative intent was to ensure consistency between the ADC and Home Relief programs to prevent shifting caseloads, despite the lack of direct federal mandate for Home Relief. The order of the lower court was modified and affirmed, with two judges dissenting.