Morris v. Com., Dept. of Social Services

Benton, J.,

dissenting.

The Fifth and Fourteenth Amendments to the Únited States Constitution guarantee that the government may not deprive a person of property without due process of law. Article I, § 11 of the Constitution of Virginia provides the same guarantee. At a minimum, the due process clauses require that any deprivation of life, liberty or property by the government “be preceded by notice . . . appropriate to the nature of the case.” Mullane v. Central Hanover Trust Co., 339 U.S. 306, 313 (1950). Even though there may be many areas of the law where notice is given only after a *86debt or liability has accrued, a constitutional limitation on government often “requires greater precautions in its proceedings than the business world accepts for its own purposes.” Id. at 319. The doctrine of necessaries, notwithstanding, the government is constrained by the due process clauses of the constitutions.

The pertinent facts as found in the trial judge’s opinion letter are as follows:

Clyde Morris married Daisy Morris prior to 1970. In 1970 a child was born, Stanley, and the parties thereafter separated in 1972. At the time of separation the parties were living in a trailer beside his father and mother-in-law in Madison County. Mr. Morris was ready to move the trailer to another location when his wife left and moved in with her parents next door. He claims that when he tried to speak to her an altercation arose and he got charged with assault and battery. This was the event of the separation and thereafter he tried to pay her support by offering her cash money for herself and the child and she refused to take it. He claims she said she did not want any support. Further, Mr. Morris testified that his mother and father tried to help her, which she refused and that he also had a place set up to for them to move but she refused that assistance as well. Mr. Morris had no contact with his wife or child from 1972 until 1983. In March of 1983 he was incarcerated in the state penitentiary system where he stayed until he was released in November of 1986.
At or about the time he was incarcerated Mrs. Morris made application for Aid to Dependent Children and listed Mr. Morris’ address as the Joint Security Complex. Later, she notified the Department that he was incarcerated and would be getting out in June of 1986. After his release he lived in Stanardsville and was never contacted by the Department of Social Services about paying child support of his child or reimbursing the state for public assistance paid for his child. The first notice he received was an administrative order entered by the Bureau of Support dated September 5, 1989. He responded to the administrative order and noted his appeal. The Bureau of Support originally wanted him to pay *87back $8,000.00, but later reduced it to $4,160.00. In June of 1988 the son turned 18 so this sum is the fixed amount in dispute.

The dispute in this case concerns what process is due a parent at the time the government makes a “payment of public assistance ... for the benefit of any dependent child . . . [and thereby] creates a debt due and owing to the [government] by the person . . . who [is] responsible for the support of such child.” Code § 63.1-251. I do not agree that Morris has not proved a due process violation. The act of paying public assistance to Morris’ wife for the benefit of their child created a debt that was due and owed by Morris and, thus, affected a deprivation of his property interests. The precise issue here is the constitutional adequacy of a statutory procedure that allows notice of the debt first to be given six years after payments were commenced, even though Morris’ exact location was known when payments commenced and during the entire six years. At a minimum, Morris was entitled to notice at the time payment of assistance commenced, which was the statutory determination that a debt was due and owing, and certainly, in any event, Morris was due notice prior to the passage of six years.

“ [Consideration of what procedures due process may require under any given set of circumstances must begin with a determination of the precise nature of the government function involved as well as of the private interest that has been affected by the governmental action.” Cafeteria & Restaurant Workers Union, Local 473 v. McElroy, 367 U.S. 886, 895 (1961). It is undisputed that the government has an interest in “promoting] the efficient and accurate [provision] of support for financially dependent children.” Code § 63.1-249. However, the government has no interest in supplanting the role of the parent as the primary source of child support. No governmental function or interest is promoted by delaying notice to a parent whose location is known when the payment of assistance is made to a dependent child. The statutory purpose is promoted by prompt notification. See Logan v. Zimmerman Brush Co., 455 U.S. 422, 434-35 (1982). Moreover, the government has not shown that it will be burdened or that the process of ensuring prompt assistance to needy dependents will suffer if notice is sent to the responsible parent at that parent’s last known address. Indeed, the application for assistance requests the address for the responsible parent.

*88The child’s mother and the governmental agency have always known where Morris was located. When the mother applied for assistance she gave his precise location, and she later gave his new location after he was transferred. It is a fundamental and long standing constitutional principle that “when notice is a person’s due, process which is a mere gesture is not due process.” Mullane, 339 U.S. at 315. Waiting six years until the child reached his majority, the government’s notice to Morris was a mere gesture and not a notice designed to allow the protection of his rights or the promotion of public policy. The right to be heard is meaningless unless the person entitled to notice receives it at a time when his or her rights can be effectively exercised. I would hold that the State may not, consistent with the obligations imposed on it by the Due Process Clauses of the.state or federal constitutions, delay for six years giving notice to a parent, whose location is known, that it seeks to obtain reimbursement for public assistance payments.

As a consequence of delaying the notice, the government not only deprived Morris of a reasonable opportunity to avail himself of other remedies, but also delayed the administrative hearing to a time when the issues that needed to be adjudicated were not seasonal.

What the constitution does require is “an opportunity . . . granted at a meaningful time and in a meaningful manner,” “for [a] hearing appropriate to the nature of the case. . . .” In short, “within the limits of practicability,” a State must afford to all individuals a meaningful opportunity to be heard if it is to fulfill the promise of the Due Process Clause.

Boddie v. Connecticut, 401 U.S. 371, 378-79 (1971)(citations omitted). Morris’ right not to be deprived of property without due process entitled him to an administrative hearing with respect to the assessed debt within a reasonable time after the governmental agency made the assessment. A delay of six years is not within the realm of reason.

We also discern little or no state interest, and the State has suggested none, in an appreciable delay in going forward with [the administrative] hearing. On the contrary, it would seem as much in the State’s interest as [the responsible parent] to have an early and reliable determination with respect *89to the [issues].

Barry v. Barchi, 443 U.S. 55, 66 (1979).

If the government had sent Morris within a reasonable time notice of the payment of assistance to his child, Morris had available to him the option of seeking a court order with respect to his support obligations. See Code § 63.1-251. At that time, Morris could have proved that the child’s mother refused support payments that he offered, that the child’s mother refused assistance for the child from Morris’ parents, and that the child’s mother rejected Morris’ offer to provide a residence for her and the child. The effect of delaying notice and a hearing for six years, which occurred after the child’s majority, deprived Morris of the opportunity to minimize his property loss through in-kind payments, including the use of the residence. Moreover, he was deprived of an opportunity to prove that the mother was not eligible for the governmental assistance or some part of it.

Although in State v. Dionne, 131 N.H. 630, 557 A.2d 653 (1989), the court concluded that no interest was served in giving notice and a hearing to a parent to contest the need for support prior to the time the state sought reimbursement from the parent, no appreciable delay occurred in that case between that payment and the notice. Id. at _, 557 A.2d at 655. The court’s emphasis on the doctrine of necessities rather than the notice requirement of the due process clause can be explained by the parent’s failure to establish that the passage of six months represented a denial of an “opportunity to be heard ‘at a meaningful time.’ ” Mathews v. Eldridge, 424 U.S. 319, 333 (1976).

The Virginia statute in question in this appeal is constitutionally infirm precisely because it does not ensure either timely notice of the debt that is due or a timely hearing after the administrative determination that a debt is due and owing. The statute contains no parameters and, thus, leaves the responsible parent subject to unlimited liability and passage of time before notice and hearing are given. “[T]he provision for an administrative hearing, neither on its face nor as applied in this case, assured a prompt proceeding and prompt disposition of the outstanding issues. . . .” Barchi, 443 U.S. at 66. “[T]he State owes to each individual that process which, in light of the values of a free society, can be characterized as due.” Boddie, 401 U.S. at 380.

*90I believe that the holdings in Gresham v. Department of Human Resources, 257 Ga. 747, 363 S.E.2d 544 (1988), and Baker v. Department of Health and Rehabilitative Services of Virginia, 526 So. 2d 1057 (Fla. App. 1988), are consistent with the requirements of due process and represent valid public policy considerations. As the Gresham court stated:

“[W]here parents are divorced and custody is awarded to one parent, where the parent not having custody has not been ordered by any court to pay child support, and where the nonpaying parent’s address is known or can be ascertained, the state . . . must notify the parent of the duty of support and of the application for AFDC payments before such parent becomes obligated to reimburse the state for such payments. [First,] we do so . . . to protect parents not otherwise subject to a court order or agreement as to child support, so that such parents may contest eligibility for AFDC payments or keep records of the support they in fact are providing. A parent should not be liable to the state for AFDC payments made, without notice to the parent, to ineligible recipients or when the parent is in fact paying for the support of a child. Second, we do so because the failure to provide for notice and an opportunity to be heard could render the state’s right to recovery unconstitutional for lack of notice and due process.”

Id. at 749-50, 363 S.E.2d at 546 (quoting Burns v. Swinney, 252 Ga. 461, 464, 314 S.E.2d 440, 443 (1984)).

Given reasonable notice of assistance, Morris could have contested the mother’s eligibility to receive payments or could have sought a change in the child’s custody status. He also could have obtained an adjudication of his inability to pay all or part of the support or to pay support in-kind by furnishing a residence to his family. Where, as here, Morris’ support obligation has not been determined by court order, the governmental delay in sending notice after six years had passed deprived Morris of the opportunity to obtain an adjudication of his obligation on the then current circumstances and allowed Morris to be subjected to an almost unlimited liability without notice to him.

For these reasons, I believe that the failure to provide notice and a hearing until the lapse of six years after the debt was ere*91ated constitutes a due process violation. Accordingly, I dissent and would reverse the judgment for this reason.