AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Samantha Rupert appealed the decision of the New Mexico Department of Human Services, which adopted the recommendation of its administrative law judge (ALJ) to terminate Rupert’s Temporary Assistance for Needy Families (TANF) cash benefits. The termination was a sanction for her noncompliance with the requirements of the Child Support Enforcement Division (CSED) (para 1).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Claimant-Appellant: Argued that the Department’s decision to terminate TANF benefits was not in accordance with the law due to untimely and substantively inadequate notices and contended that the ALJ’s finding of noncompliance with CSED requirements was not supported by substantial evidence (paras 2, 5, 10).
• Respondent-Appellee: Defended the decision to terminate TANF benefits, asserting that the decision was in accordance with the law and supported by substantial evidence, including compliance with notice requirements and evidence of noncompliance with CSED requirements (paras 2, 5, 10).

Legal Issues

• Whether the Department’s decision to terminate TANF benefits was in accordance with the law, considering the timeliness and adequacy of the notices provided to Rupert.
• Whether the ALJ’s finding that Rupert was noncompliant with CSED requirements was supported by substantial evidence.

Disposition

• The Court of Appeals affirmed the Department’s decision to terminate Rupert’s TANF benefits as a sanction for her noncompliance with CSED requirements (para 14).

Reasons

• The Court, consisting of Chief Judge Jennifer L. Attrep, Judge Kristina Bogardus, and Judge Gerald E. Baca, provided the following reasons for their decision:
  On the Timeliness and Adequacy of Notices: The Court declined to address the timeliness argument because it was not raised at the administrative hearing before the ALJ and therefore was not preserved for review. Regarding the adequacy of the notices, the Court found Rupert’s arguments to be undeveloped and unsupported by authority, thus declining to consider them further (paras 4-8).
  On Substantial Evidence of Noncompliance: The Court rejected Rupert’s challenge to the sufficiency of the evidence supporting her noncompliance with CSED requirements. It noted that Rupert’s hearsay-based argument was not preserved at the administrative hearing. Furthermore, the Court found no persuasive reason to conclude that hearsay evidence was insufficient to support a finding of noncompliance, especially given the statutory and regulatory provisions that formal rules of evidence do not apply to the fair hearing process (paras 10-13).