Wheaton v. Department of Health & Human Services

Summary

The Maine Supreme Judicial Court affirmed the denial of food stamp benefits to Tammie Wheaton. It held that unrestricted monthly payments received under a divorce property settlement constituted household income under federal food stamp regulations and were not an excluded category of income.

Holdings

1. The $500 monthly payments constituted household income because the governing statute and regulation define income broadly as all income from whatever source, subject only to specified exclusions, and no applicable exclusion covered these payments.
2. The Department's construction of the governing regulation was reasonable, and a contrary result was not plainly compelled; therefore, the court upheld the agency's determination.

Questions Presented

1. Whether $500 monthly payments received under a divorce property settlement agreement constitute household income under the federal food stamp statutes and regulations.
2. Whether the Department of Health and Human Services reasonably construed the governing food stamp regulations in determining that the payments were not an excluded type of income.

Disposition

affirmed