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

• Suzanne Calles applied for Temporary Assistance for Needy Families (TANF) benefits for herself and her child, R.G., after R.G. was conditionally released to her custody. Previously, the Children, Youth and Families Department (CYFD) had placed R.G. in his father's custody, and the father had been granted TANF benefits for R.G. Calles's application was denied by the Human Services Department (HSD) on the grounds that R.G. was considered to reside primarily with his father, despite evidence presented by Calles demonstrating that R.G. resided with her the majority of the time and that she was primarily responsible for his care and support.

Procedural History

• Appeal from a final decision of the New Mexico Human Services Department, Aldo Jadnicek, Administrative Law Judge: The HSD denied Calles's application for TANF benefits.

Parties' Submissions

• Plaintiff-Appellant: Argued that the denial of TANF benefits was in error, presenting evidence that R.G. resided primarily with her and that she exercised parental control and was primarily responsible for his care and support.
• Defendant-Appellee: Opposed the summary disposition proposed by the Court, asserting that the denial of benefits was correct based on the policy and evidence indicating R.G. resided with his father.

Legal Issues

• Whether it was reversible error for HSD to deny Calles’s application for TANF based on the policy, despite evidence showing her child resided primarily with her and she was responsible for his care.
• Whether it was reversible error for HSD to deny Calles’s application for TANF where HSD has the burden to prove its action was reasonable, and Calles presented an unrebutted prima facie case.

Disposition

• The Court of Appeals reversed HSD’s denial of TANF benefits to Calles and remanded for further proceedings consistent with the Opinion.

Reasons

• Per Roderick T. Kennedy, J. (Linda M. Vanzi, J., J. Miles Hanisee, J., concurring): The Court found that the decision by HSD was not supported by substantial evidence in the record as a whole. The Court noted that Calles had taken on the responsibilities of care and support for R.G. as evidenced by the conditions of release she signed and a school attendance contract. The Court also found that the policy clarification cited by HSD did not apply to the TANF program and that Calles had presented ample evidence that R.G. lived with her and she was responsible for his supervision and care. The Court concluded that Calles's application for TANF benefits should have been approved, reversing the hearing decision and remanding to HSD for further proceedings consistent with the Opinion.