Reimbursement of Funds for Job Training Programs

The central issue in Mississippi Department of Economic & Community Development v. United States Department of Labor, 90 F.3d 110 (5th Cir. 1996) concerned the validity of the Secretary of Labor's order requiring reimbursement to the federal government of funds provided under the Job Training Partnership Act. As the court explained in Mississippi, the Act allocates federal monies to state governments for job training and placement programs for economically disadvantaged persons. Mississippi, 90 F.3d at 111. Pursuant to the Act, funds were dispensed to the designated agent for the Governor of Mississippi, the Mississippi Department of Economic and Community Development ("MDECD"). Id. A division of the MDECD, the Mississippi Service Delivery Area, used the funds to implement workforce development programs at the county level. Id. Still another subdivision of the MDECD, the Mississippi Employment Service Commission, received government funds for job training and referral services. Id. While the question of whether these various entities qualified as governmental agencies was not directly raised, the court referred to the entities as "state agencies" and addressed a defense applicable only to governmental units of a state. Mississippi, 90 F.3d at 111-112.