Idabelle Benton and William Wisebaker v. James A. Rhodes, Governor, State of Ohio, and Raymond McKenna Director, Ohiodepartment of Public Welfare

KEITH, Circuit Judge,

concurring in the judgment.

I concur in the majority’s judgment which holds that the preliminary injunction issued in this case should be vacated for the reason that no hearing requirement exists when either state or federal law requires automatic grant adjustments. 45 C.F.R. § 205.10(a)(5); see also Jennings v. Solomon, Civ.No. Y-75-1869 and Y-76-210 (D.Md. Nov. 4, 1976).

I disagree with the majority’s finding, however, that the notice of termination sufficiently complied with the regulations. Under Section 205.10(a)(4), the intended action of the Department of Public Welfare was an action “to discontinue, terminate, suspend or reduce assistance.” This being so, Section 205.10(a)(4) goes on to provide the following:

(i) The State or local agency shall give timely and adequate notice, except as provided for in paragraphs (a)(4)(ii), (iii), or (iv) of this section. Under this requirement:

(A) “Timely” means that the notice is mailed at least 10 days before the date of action, that is, the date upon which the action would become effective;

(B) “Adequate” means a written notice that includes a statement of what action the agency intends to take, the reasons for the intended agency action, the specific regulations supporting such action, explanation of the individual’s right to request an evidentiary hearing (if provided) and a State agency hearing, and the circumstances under which assistance is continued if a hearing is requested;

(iii) When changes in either State or Federal law require automatic grant adjustments for classes of recipients, timely notice of such grant adjustments shall be given which shall be “adequate” if it includes a statement of the intended action, the reasons for such intended action, a statement of the specific change in law requiring such action and a statement of the circumstances under which a hearing may be obtained and assistance continued.

There are thus four requirements which must be met in order to comply with the adequate notice provisions of the regulation: (1) a statement of the intended action, (2) the reasons for the intended action, (3) a statement of the change in law requiring the action, and (4) a statement setting forth the circumstances under which a hearing may be had and assistance continued. The majority opinion notes only that the notice adequately advised recipients of the reasons for the intended reductions. The notice, however, did not set forth the circumstances, if any, under which a hearing might be had or assistance continued and therefore did not comply with the notice provisions of the regulations. Nevertheless, this court having found that no hearing is required, a finding with which I concur, it would be *5pointless to hold that benefits must be continued until adequate notice is given to recipients, which notice would only inform them that they have no present right to a hearing. See Jennings v. Solomon, supra at 15. For these reasons, I concur in the judgment of the court.