## Facts

- Connecticut operated a state-mandated general assistance (GA) program providing financial and medical aid to indigent residents who did not qualify for other programs.
- Municipalities administered GA; municipalities paid administrative costs and 20% of benefits, with the state reimbursing 80%.
- In 1993, Connecticut enacted General Statutes (Rev. to 1993) § 17-273b, limiting GA cash benefits for “employable” recipients to nine months in any twelve-month period.
- Hamilton Moore and two other Bridgeport residents were employable GA recipients whose cash benefits were scheduled to terminate after nine months under § 17-273b.
- The plaintiffs claimed the Connecticut Constitution imposes an affirmative obligation on the state to provide indigent residents a minimal level of subsistence and that the durational limit violated that obligation.
- The defendants included Bridgeport officials and the City of Bridgeport; the State of Connecticut and state officials participated because the challenged scheme was mandated by state law.

## Issues

1. Whether the Connecticut Constitution imposes an affirmative, judicially enforceable duty on the state to provide indigent residents a minimal level of subsistence.
2. Whether § 17-273b’s nine-month durational limit on GA cash assistance for employable recipients is unconstitutional under the Connecticut Constitution.
3. What level of judicial review applies to a legislative decision limiting welfare benefits for employable recipients.

## Decision

- The Connecticut Supreme Court affirmed the trial court’s denial of a temporary injunction.
- The court held that the Connecticut Constitution does not impose an affirmative duty on the state to provide the subsistence benefits sought by the plaintiffs.
- The court treated constitutional references to social welfare as aspirational policy statements rather than self-executing, enforceable entitlements.
- The court declined to constitutionalize benefit levels or duration, emphasizing that welfare design and funding are primarily legislative determinations.
- The court rejected the contention that the durational limit violated other specific constitutional guarantees, concluding the scheme was justified by legitimate fiscal and policy objectives under a deferential standard.

## Legal Principles

- Absent clear constitutional text creating an enforceable entitlement, courts will not infer an affirmative constitutional right to government-provided minimum subsistence.
- Provisions expressing general social-policy goals do not, without more, create self-executing rights to specific welfare benefits.
- Decisions regarding the level, form, and duration of welfare assistance involve budgetary and policy judgments generally committed to the political branches.
- Welfare classifications affecting employable recipients are reviewed deferentially when they do not implicate suspect classifications or fundamental rights; fiscal restraint and encouraging employment can supply a rational basis.

## Conclusion

The court upheld Connecticut’s nine-month limitation on GA cash benefits for employable recipients, ruling that the state constitution does not create a judicially enforceable affirmative right to a minimum level of subsistence and leaving welfare benefit design to the legislature.


Moore v. Ganim, 233 Conn. 557, 660 A.2d 742 (Conn. 1995)