Allen v. State Dep't of Health & Soc. Servs., Div. of Pub. Assistance

In Allen v. State Dep't of Health & Soc. Servs., Div. of Pub. Assistance, 203 P.3d 1155, 1167-68 (Alaska 2009), food stamp recipients received excess benefits due to errors made by a state agency, and the agency pursued an overpayment claim. 203 P.3d at 1158-59. Following a ruling in favor of the agency, the recipients challenged the sufficiency of the notice. Id. at 1159. The Alaska Supreme Court reversed, finding that the notice failed to comply with applicable regulations, which are "a prerequisite to bringing a recoupment action." Id. at 1169. The court reasoned that a notice lacking in sufficient detail requires a benefits recipient to blindly rely "on the calculations of an agency that has admittedly already made a calculation error to that recipient's detriment." Id. The court thus concluded it would be unfair, and a violation of due process, to hold the recipient liable for the Department's own errors without providing her with sufficient information to allow her to understand how the Department arrived at its decision. Id.