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

• The case involves the appellant, Racheal Enoah, who applied for and was receiving benefits under the Temporary Assistance for Needy Families (TANF) program. After being approved for limited participation due to domestic violence issues, Enoah agreed to complete eighty-six hours per month of activities, including community service and participation in domestic violence counseling. She was later informed that she needed to provide verification for the activities listed on her July time sheet, a requirement she claimed to be unaware of. The Department of Human Services (Department) imposed a third-level sanction, terminating her TANF benefits for failing to provide the required verification (paras 2-5).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant: Contended that the sanction was invalid because, as a recipient approved for limited participation, she could not be required to commit to eighty-six hours per month. Argued that the work participation agreement was void due to this invalid requirement and that substantial evidence did not support the Department's finding that she had been timely notified of the verification requirement for her time sheets (paras 6, 8, 12).
• Appellee (Department): Maintained that the sanction was valid and that the appellant had been properly notified of the requirement to verify activity hours. Argued that the work participation agreement was valid and that the appellant's failure to provide verification warranted the sanction imposed (paras 7, 9, 14-15).

Legal Issues

• Whether the work participation agreement was void due to an invalid hourly requirement imposed on a recipient approved for limited participation.
• Whether substantial evidence supported the Department's finding that the appellant had been timely notified of the requirement to verify her activity hours on the time sheet.

Disposition

• The Court of Appeals affirmed the Department's decision to uphold the sanction terminating the appellant's TANF benefits (para 1).

Reasons

• Cynthia A. Fry, Judge (with James J. Wechsler, Judge, and Linda M. Vanzi, Judge concurring): The court found that the appellant's status as a limited work participant allowed for flexibility in the activities assigned to her and did not necessarily exempt her from completing eighty-six hours of work participation per month. The court also determined that the regulations did not require that a participant with limited work participation status be assigned fewer hours. Furthermore, the court concluded that substantial evidence supported the Department's finding that the appellant had been timely notified of the verification requirement, noting that hearsay evidence is admissible in administrative hearings and that the legal residuum rule was satisfied. The court emphasized the importance of the appellant's responsibility to keep the Department informed of her current mailing address (paras 7-18).