The Michigan Court of Appeals considered several issues with respect to cash-assistance benefits under the Family Independence Program (FIP) in the consolidated appeals of Smith v. Department of Human Services Director.
In this case, the plaintiffs challenged the Department of Human Services (DHS) Director's authority to impose a 60-month time limit on their cash-assistance benefits under the FIP. First, the Court disagreed with the circuit court's determination that the DHS Director violated the separation of powers doctrine by imposing the benefits time limit. Instead, the Court held that the applicable statutes showed a clear legislative intent to allow the DHS to add eligibility criterion to the assistance program, particularly because the Director relied on fiscal soundness when making the decision to cut off the funds. Next, the Court affirmed in part and reversed in part the circuit court's determination that the DHS violated the rulemaking procedures of the Administrative Procedures Act (APA) by implementing the funding limit. The Court held that, to the extent that federal funds were cut off after the 60-month time limit, the circuit court had erred because the DHS was following a federal mandate requiring that certain funds be limited to a cumulative period of no more than 60 months. However, the Court noted that no such mandate existed as applied to state funds. Accordingly, the Court held that, to the extent that the plaintiffs were entitled to FIP benefits derived from state funds, the circuit court was correct in finding a violation of the APA. Finally, the Court upheld the circuit court's issuance of class certification, reasoning that the DHS Director failed to show any basis for reversal of the circuit court's finding that class action was a superior means of adjudicating the legal question presented in this case.