Did Formula for Allocation of Funds to Senior Citizens Discriminate Against Minority Seniors ?

In Meek v. Martinez (724 F Supp 888 [1987]), plaintiffs claimed that Florida's formula for allocating funds to senior citizens pursuant to the Act discriminated against minority seniors. The court compared the effects of the State's allocation formula with a stripped down version of the State's formula that excluded certain elements that plaintiffs claimed favored White seniors. Under the statute, funds were distributed to geographically defined districts, known as planning and service areas (PSAs). The court found a disparate impact when it compared the amount of funding directed under the two formulas to the four highest and four lowest percentage minority PSAs in Florida. The high percentage minority PSAs received less funding under the State's formula than they did under the alternate formula (Meek, 724 F Supp, at 906). The Meek court ultimately found that this disparate impact could not be justified by any valid State policy and so held that Florida's distribution of funds under the Older Americans Act violated title VI regulations promulgated by the United States Department of Health and Human Services.