Bennett v. Kentucky Department of Education

In Bennett v. Kentucky Department of Education, 470 U.S. 656, 669, 105 S.Ct. 1544, 84 L.Ed.2d 590 (1985), the Department sought to recover funds it had disbursed to the state, on the grounds that the state had misused funds meant "to supplement, and not to supplant, state and local expenditures for education." 470 U.S. at 658, 105 S.Ct. 1544. The question before the Supreme Court was whether, in "excusing the State from repayment on the grounds that there was no evidence of bad faith and the State's programs complied with a reasonable interpretation of the law," the court of appeals had applied an erroneous standard of review. Id. at 659, 105 S.Ct. 1544. The Supreme Court reversed "because we disagree with the standard adopted by the Court of Appeals." Id. In Bennett v. Kentucky Department of Education, 470 U.S. 656, 669, 105 S.Ct. 1544, 84 L.Ed.2d 590 (1985), Kentucky argued that a federal-state grant agreement "should be viewed in the same manner as a bilateral contract." The Court rejected this approach, holding that, "unlike normal contractual undertakings, federal grant programs originate in and remain governed by statutory provisions expressing the judgment of Congress concerning desirable public policy." Id.