Saunders v. Trump

Background

Diane Saunders received Supplemental Nutrition Assistance Program benefits. St. Louis County notified her by letter dated September 20, 2017, that her benefit amount would be reduced beginning in October 2017. Saunders contacted the county on September 26, 2017, to say that she wanted to appeal. More than ten weeks later, she had not received information about her requested appeal or the appeal process.

Saunders sued the United States; Donald J. Trump, in his official capacity as President; Sonny Perdue, in his official capacity as Secretary of Agriculture; Emily Piper Johnson, in her official capacity as Minnesota Commissioner of Human Services; and Linnea Mirsch, in her official capacity as Director of St. Louis County Public Health and Human Services. She alleged constitutional, statutory, and regulatory violations based on the benefit reduction, the notice she received, and the alleged failure to provide a fair hearing. She sought injunctive and declaratory relief, costs, disbursements, and attorneys’ fees.

Magistrate Judge’s Recommendation

The magistrate judge recommended granting the defendants’ motions to dismiss and denying Saunders’s motion for a preliminary injunction as moot. The recommendation concluded that Saunders could not obtain a retrospective declaration that the Commissioner had violated the law in the past. It also concluded that any request for a prospective injunction requiring a hearing was moot because Saunders received an administrative hearing in March 2018 and her benefits were restored while her appeal continued.

As to the County, the recommendation concluded that Saunders had not identified an official policy or custom causing the alleged constitutional violations. It also concluded that she had not alleged facts establishing that the County’s notice was untimely or inadequate. As to the federal defendants, the recommendation concluded that they had not waived sovereign immunity, which generally protects the United States and its officials from certain lawsuits seeking relief. It further concluded that Saunders failed to state a claim under the Administrative Procedure Act because the challenged regulations were either adopted after notice and an opportunity for comment or expressly exempt from those requirements.

District Court’s Analysis

The court reviewed the parts of the recommendation to which Saunders objected independently and reviewed the remaining portions for clear error. Saunders argued that the recommendation incorrectly stated that she had received two fair hearings. The court said that any error about the number of hearings did not matter because Saunders did not dispute that she received a fair hearing or that her benefits were restored pending her appeal. The court also noted that her complaint alleged a complete denial of a hearing and sought an injunction requiring a hearing; it did not allege harm from a delay or seek relief for delayed processing.

Saunders conceded that the County’s notice met the regulatory timing requirement. She argued instead that the ten-day notice period was inadequate and that the letter did not provide enough detail about the benefit reduction. The court concluded that disagreement with the regulation did not state a claim against the County, that the letter gave the reason for the reduction as required by the regulation, and that Saunders cited no legal authority requiring more detail. The court also noted that a constitutional notice claim against the County would require identification of an official policy or custom, which Saunders had not done.

Disposition

The court overruled Saunders’s objections and adopted the magistrate judge’s report and recommendation. It granted Emily Piper Johnson’s motion to dismiss, granted Linnea Mirsch’s motion to dismiss, and granted the United States, Donald J. Trump, and Sonny Perdue’s motion to dismiss. It denied Saunders’s motion for a preliminary injunction as moot and dismissed the matter without prejudice. The order directed that judgment be entered accordingly.