## Facts

- The Indiana Family and Social Services Administration (FSSA) used an automated system to process applications for Medicaid, Food Stamps, and Temporary Assistance to Needy Families (TANF).
- Sheila Perdue and certified classes of benefits applicants challenged adverse eligibility determinations and related agency practices.
- Class A and Sub-class A alleged FSSA denial notices for Medicaid, Food Stamps, and TANF were constitutionally and regulatorily deficient because they did not adequately explain the reasons for denials.
- Class C challenged Food Stamp denials based on “failure to cooperate” in the eligibility determination process, arguing federal law permitted denial only for “refusal to cooperate.”
- Perdue individually alleged that FSSA failed to provide reasonable disability accommodations in benefits application/recertification processes, resulting in discontinuation of her Food Stamp and Medicaid benefits.
- The trial court upheld the denial notices for Class A/Sub-class A, ruled for Class C on the “failure” versus “refusal” issue, and granted summary judgment to Perdue on her ADA/Rehabilitation Act claims.
- The Court of Appeals reversed on notice adequacy, and affirmed on Class C and Perdue’s disability-accommodation claims.

## Issues

1. Whether FSSA’s automated denial notices for Medicaid, Food Stamps, and TANF provided sufficiently specific reasons to satisfy due process and applicable federal requirements.
2. Whether federal Food Stamp law permits denial of benefits when an applicant fails to cooperate in the eligibility determination process, as opposed to only when the applicant refuses to cooperate.
3. Whether FSSA violated the ADA and Rehabilitation Act by failing to provide reasonable accommodations to Perdue in applying for and maintaining benefits.

## Decision

- The Indiana Supreme Court held FSSA’s denial notices were constitutionally inadequate because they were insufficiently explanatory, and reversed the trial court on Class A/Sub-class A.
- The Court held FSSA may deny Food Stamp applications when an applicant fails to cooperate in the eligibility process, and reversed the contrary rulings for Class C.
- The Court affirmed in part summary judgment for Perdue, holding she was entitled to reasonable accommodations, while clarifying that accommodations do not necessarily require a dedicated caseworker or case-management services.
- The case was remanded for relief consistent with these holdings.

## Legal Principles

- Due process in public-benefits determinations requires notice that provides enough individualized explanation for an applicant to understand the agency’s action and prepare for an appeal or hearing; conclusory “ultimate reason” statements may be insufficient.
- Use of automated processing is not categorically unlawful, but the resulting notices must still disclose the specific factual basis for the adverse determination.
- Under federal Food Stamp eligibility rules, a state agency may deny an application when the applicant’s noncooperation prevents eligibility verification; the controlling question is whether the applicant’s conduct constituted noncooperation and whether the agency adequately explains that basis.
- The ADA and Rehabilitation Act require reasonable modifications to policies and procedures to ensure meaningful access to benefits programs, but they do not guarantee a particular accommodation (such as assignment of a caseworker) if other effective options are reasonable.

## Conclusion

The Indiana Supreme Court required FSSA to issue more specific and informative denial notices for public benefits, permitted Food Stamp denials based on failure to cooperate with eligibility verification, and confirmed that disabled applicants are entitled to reasonable accommodations without mandating a specific service model.


Perdue v. Gargano, 964 N.E.2d 825 (Ind. 2012)