## Facts

- Michigan administered cash assistance through the Family Independence Program (FIP) under the federal TANF block grant.
- Michigan adopted a policy that terminated an entire household’s FIP benefits if a household member failed, without good cause, to cooperate for at least four consecutive months in establishing paternity or pursuing child support.
- Michigan applied the same sanction to the food-stamp program, terminating the entire household’s food stamp benefits based on the caretaker’s non-cooperation.
- Ethan Walton, a minor, lived in a household headed by his mother, Antoinette Walton.
- Antoinette had established paternity and child support for Ethan but not for another child in the household.
- The agency found Antoinette non-cooperative and notified her that the entire family’s food stamp benefits would be terminated.
- Ethan, through representatives, sued the state agency director in federal court, alleging the policy conflicted with the Food Stamp Act as amended by PRWORA.
- The district court granted summary judgment for Ethan, holding the director exceeded authority under the Food Stamp Act by denying benefits to the whole household; the director appealed.

## Issues

1. Whether the Food Stamp Act, as amended by PRWORA, authorized a state to impose a household-wide food stamp disqualification when non-cooperation in establishing paternity/child support was attributable to a single household member.
2. Whether statutory provisions permitting coordination of TANF and food stamp sanctions allowed a state to extend a sanction beyond the non-cooperative individual to all household members.

## Decision

- The Sixth Circuit affirmed the grant of summary judgment for Walton.
- The court held Michigan’s policy terminating the entire household’s food stamp benefits based on the custodial parent’s non-cooperation exceeded authority granted by the Food Stamp Act as amended by PRWORA.
- The court concluded the district court’s interpretation matched the statutory text and legislative intent.

## Legal Principles

- Food stamp eligibility and sanctions are governed by federal statutory limits; states may coordinate with TANF sanctions only to the extent the Food Stamp Act expressly permits.
- Where the statute specifies disqualification of a non-cooperative individual (and, where stated, the head of household), a state may not impose a broader, household-wide disqualification by implication.
- PRWORA’s welfare reforms did not convert the food stamp program into a block grant; Congress retained federal control and a uniform federal “safety net,” constraining state discretion to expand sanctions.

## Conclusion

The Sixth Circuit held that Michigan could not terminate an entire household’s food stamp benefits solely because a caretaker failed to cooperate in establishing paternity for one child, because the Food Stamp Act did not authorize that household-wide sanction.


Walton v. Hammons, 192 F.3d 590 (6th Cir. 1999)