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Question
Section 320, added in 1975 to the New York State Welfare Code, created a special welfare grant to replace clothing or furniture lost in "fire, flood, or like catastrophe." The legislative committee report with the bill explained that its purpose was to replace discretionary grants, which were often abused, and were demeaning for recipients to request. The State Department of Social Services interpreted the statute to exclude grants for losses resulting from human causes.
Ms. Howard, a welfare recipient, a single parent, lives in a slum apartment that was burglarized, and lost about $2,000 of her clothing and furniture. Her application for a special grant under § 320 and her fair hearing appeal were rejected based on the manual. She appealed to the courts. What resulted? Why?
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