Marion J. Woods, Director of the State Department of Social Services v. United States

This is an appeal from the judgment of the district court granting the United States Department of Agriculture’s (USDA) motion for summary judgment in an action brought by the California Department of Social Services to challenge the decision of the Food Stamp Appeals Board upholding the USDA’s claim in the amount of $234,842.00, for violations of the Food Stamp Act of 1964 during the period of November 15, 1976 to May 31, 1977.

We must decide: (1) whether the Secretary of Agriculture may recover from the State of California losses to the Federal Treasury caused by San Francisco when it shifted its welfare burden to the federal government; (2) whether the Secretary is estopped from asserting his claim against the state because of his failure to join in state court proceedings brought by welfare recipients challenging San Francisco’s actions; (3) whether the district court erred in determining that the damages suffered by the federal government were properly calculated. We find that the Secretary has an implied right of action under section 10(d) of the Food Stamp Act to recoup losses stemming from misuse of the food stamp program, that the state is responsible for San Francisco’s…