Department of Health and Welfare, State of Idaho v. John Block, Secretary of Agriculture

The Secretary of Agriculture appeals from an order entered by the Idaho District Court which enjoined the Secretary from enforcing a policy, embodied in a regulation, that disallowed consideration of vendor-paid energy costs in determining food stamp benefit eligibility. The case presents questions of statutory interpretation involving provisions of two statutes under which federal funding is made available to aid eligible citizens. In dispute is the impact of home energy assistance payments made pursuant to the Low Income Home Energy Assistance Act (LIHEAA), 42 U.S.C. § 8621 et seq., upon the eligibility and benefit levels of recipients of food stamp benefits under the Food Stamp Act, 7 U.S.C. § 2011 et seq.

In a memorandum opinion and order issued on December 21, 1984, the district court ordered the Secretary to rescind all “quality control variances” (federal sanctions which could result in a state’s loss of federal food stamp funding) upon appellee State of Idaho, Department of Health and Welfare (Idaho), resulting from Idaho’s allowance of LIHEAA reimbursed home energy costs in determination of the “excess shelter expense deduction” (an element of the computation of food…