Lash v. Blum
This CPLR article 78 proceeding reviewed a determination by the Commissioner of the New York State Department of Social Services to reduce the petitioner's public assistance benefits. The reduction was based on an alleged fraudulent failure to report workers' compensation benefits received by the petitioner's husband. The court annulled the Commissioner's determination, finding that the claim of willful withholding was unsupported by evidence, as the agency had prior notice of the benefits. Additionally, the court ruled that recoupment was improper because the funds were no longer an available resource after being used to repay a loan, and the agency's notice of intent was constitutionally deficient. The petition was granted, benefits were ordered restored, and the matter was remitted for a determination on counsel fees.