Case: Reynolds v. Giuliani
1:98-cv-08877 | U.S. District Court for the Southern District of New York
Filed Date: Dec. 16, 1998
Case Ongoing
Clearinghouse coding complete
Case Summary
New York City implemented an overhaul to its welfare system in order to meet federal and state welfare requirements, which were revised in the mid-1990s. Under the city’s program, “income support centers” (locations where public assistance benefits were applied for and distributed, sometimes during the initial visit by an applicant) were to be converted to “job centers.” These job centers put greater emphasis on making sure those receiving public assistance obtained employment from the private sector while doing so and added bureaucratic layers to the application process for public assistance compared to income support centers. Over half of the city’s income support centers had been converted to job centers at the time the suit was filed.
The plaintiffs each claimed to be qualified welfare beneficiaries who had been improperly denied assistance by one of the job centers in violation of the Fourteenth Amendment's Due Process clause, the city’s obligations under 7 U.S.C. §2020 (the Supplemental Nutritional Assistance Program—then referred to as Food Stamps), and 42 U.S.C. §1396 (Medicaid). The plaintiffs also alleged state law violations. They sought class certification for all similarly situated New York City residents, as well as declaratory and injunctive relief. The case was filed in the U.S. District Court for the Southern District of New York on December 16, 1998, with Judge William H. Pauley presiding.
The plaintiffs sought a temporary restraining order (1) enjoining the city from converting further income support centers into job centers; and (2) directing the city to expeditiously process the applications of the named plaintiffs. The court entered a temporary restraining order on the same day directing the city to provide emergency food stamps and cash assistance to the named plaintiffs.
The court granted a preliminary injunction to the plaintiffs on January 21, 1999. Finding the plaintiffs and others like them would suffer irreparable harm without intervention and that the evidence showed the conversion of income support centers to job centers was done with insufficient self-study and a statistical drop in the number of successful applicants for emergency assistance despite legal obligations, the court ordered the city to (1) allow applicants for public assistance to apply for benefits the first day they visit a job center, (2) cease conversion of income support centers to job centers without a formal hearing, (3) make eligibility requirements for food stamps and Medicaid separate from the eligibility determination from cash assistance, (4) send applicants timely notice of the city’s decision on whether they qualify for benefits, and (5) form a corrective plan for achieving its policy goals while also meeting the needs of public assistance applicants.
The city submitted a corrective action plan and requested modification to the preliminary injunction in March of 1999. On May 24, 1999, the preliminary injunction was modified to allow the closure of up to three more income support centers after an individualized hearing on the adequacy of city audit procedures. The court also approved of the city’s corrective action plan in the same order.
The city moved to vacate the preliminary injunction on December 10, 1999, after procuring more evidence surrounding the efficacy of the job centers in achieving their welfare obligations. Meanwhile, the State of New York moved to dismiss the complaint against them for failure to state a claim. Judge Pauley denied both motions and granted the plaintiff’s motion for class certification on July 21, 2000. The certified class consisted of "all New York City residents who have sought, are seeking, or will seek to apply for food stamps, Medicaid, and/or cash assistance at a Job Center."
Following a September 2000 audit of the city’s welfare distribution schematic, the court entered a permanent injunction in favor of the plaintiffs on December 30, 2004. The permanent injunction directed both the city and state to: (i) provide expedited food stamp service to eligible applications within 7 days; (ii) separately process applications for food stamps when the applications for cash assistance are denied or withdrawn; (iii) send notices to applicants confirming voluntary withdrawals for Medicaid in accord with 42 C.F.R. 435.913 and document such withdrawals pursuant to 7 C.F.R. 273.2(c)(6); and (iv) provide adequate and timely notice by correctly completing certain documentation. The injunction also required the state to supervise the city and make sure it met the obligations of the injunction.
On January 13, 2005, the plaintiffs moved for reconsideration of the part of the December order in which the court concluded that 8 N.Y.C.R.R. § 387.8(a)(2)(i)(a) did not confer a privately enforceable right of action and that plaintiffs’ claim under New York Social Services Law § 133 was barred by the doctrine of sovereign immunity. The court granted the motion and reversed its earlier decisions on these points on February 14, 2005. Final judgement was entered on December 14, 2005; at this time, the court also granted the plaintiffs a declaratory judgment that city officials had failed to provide the class with the obligations required of them by the relevant federal programs and further specified the parameters of the permanent injunction.
A stipulation and order resolving the issue of attorney fees was reached on January 31, 2007. The city agreed to pay the plaintiff class a total of $2,559,675.94 for the attorneys' fees incurred up through December 14, 2005. The state agreed to pay $639,918.98 for the plaintiffs' fees for the same period.
Both the state and the city appealed the permanent injunction to the U.S. Court of Appeals for the Second Circuit on January 12, 2006, but the city dropped its appeal shortly afterward. On October 31, 2007, the Second Circuit reversed the district court, ruling that the state did not have a non-delegable duty to administer the decentralized Medicaid and Food Stamp programs, the state’s efforts in supervising the city since the permanent injunction was issued were adequate, and the district court exceeded its authority by issuing a permanent injunction despite New York State’s affirmative supervisory steps it had taken to assure compliance. The Second Circuit ruling dismissed the claims against the state defendants, reversed the permanent injunction, and altered those parts of the December 14, 2005 judgement addressing the state government.
In a second stipulation and order from April 23, 2010, the City of New York agreed to pay a further $275,000.00 to the plaintiffs for attorney fees and costs from December 15, 2005 through December 14, 2008. A third stipulation and order from December 22, 2010, had the New York City Human Resources Administration (HRA), the agency in charge of implementing the changes at issue in this case, identify households which required but did not receive a separate food stamp determination between December 15, 2005 and November 30, 2006, as a result of an application at a job center in which a request for public assistance was denied, and restore those benefits.
A final stipulation and order was issued on July 22, 2011, in which the city agreed to pay $86,000.00 in attorneys' fees and costs sought to the plaintiffs for the period between December 15, 2008 and June 14, 2010.
On December 18, 2023, the plaintiffs filed a motion for civil contempt, sanctions, and attorney fees. The plaintiffs alleged that the City of New York had failed to comply with the terms of the December 14, 2005 injunction and sought to enforce the judgment. They also requested sanctions for the city’s alleged non-compliance and attorney fees incurred since December 14, 2008. The case was reassigned to Judge Lewis J. Liman on December 21, 2023.
A contempt hearing was held on February 8, 2024. The parties reached a settlement agreement on a corrective action plan on April 18, 2024 to resolve the plaintiffs’ motion for civil contempt without the court making a finding regarding the motion. Defendants agreed to various corrective actions, including implementing a management tool to track Expedited Supplemental Nutrition Assistance Program (ESNAP) cash assistance applicants, training for workers processing ESNAP benefits, providing monitoring data, adapting signage and website language for applicants, and more for a period of nine months. Plaintiffs agreed to provide their attorneys’ billing records and a settlement demand for attorneys’ fees within 30 days; if parties were unable to settle the plaintiffs’ fees claim, they were to provide the court with a status letter and a proposed briefing schedule for any fees motion by August 15, 2024.
The parties filed a status report on August 15, 2024. They filed a proposed stipulation and order on attorneys’ fees on November 15, 2024. On November 18, 2024, parties agreed to settle plaintiffs’ attorneys’ fees and costs for $280,000.
Plaintiffs motioned to extend the corrective action plan by six months on April 30, 2025, and their motion was denied on July 9, 2025.
Summary Authors
John Duffield (7/22/2021)
Amanda Gao (10/27/2025)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/12084721/parties/reynolds-v-giuliani/
Cardamone, Richard J. (New York)
Akhtar, Saima A (New York)
Banks, Steven (New York)
Biberman, Abby Judith (New York)
Callagy, Anne (New York)
Biberman, Abby Judith (New York)
Carden, Constance P. (New York)
Deabler-Meadows, Katharine (New York)
Goldfein, Joshua E. (New York)
Jeffrey, Randall S. (New York)
Josephson, Edward Joseph (New York)
Kelleher, Kathleen M. (New York)
Lamb, Christopher D. (New York)
Lee, Hwan-Hui Helen (New York)
Rosenberg, Scott Alan (New York)
Documents in the Clearinghouse
Resources
Docket
See docket on RECAP: https://www.courtlistener.com/docket/12084721/reynolds-v-giuliani/
Last updated March 20, 2026, 5:29 a.m.
Case Details
State / Territory:
Case Type(s):
Public Benefits/Government Services
Special Collection(s):
Key Dates
Filing Date: Dec. 16, 1998
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
All New York City residents who have sought, are seeking, or will seek to apply for food stamps, Medicaid, and/or cash assistance at a Job Center.
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
City
City of New York
New York City Human Resources Administration
State
New York State Department of Health
New York State Office of Temporary and Disability Assistance
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Due Process: Procedural Due Process
Other Dockets:
Southern District of New York 1:98-cv-08877
U.S. Court of Appeals for the Second Circuit 06-00284
U.S. Court of Appeals for the Second Circuit 06-00283
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Granted:
Injunction / Injunctive-like Settlement
Preliminary injunction / Temp. restraining order
Source of Relief:
Form of Settlement:
Content of Injunction:
Amount Defendant Pays: 3,840,594.92
Order Duration: 1999 - 2007
Issues
General/Misc.:
Public benefits (includes, e.g., in-state tuition, govt. jobs)
Benefits (Source):
Temporary Assistance for Needy Families (TANF)
Case Summary of Reynolds v. Giuliani, Civil Rights Litig. Clearinghouse, http://www.dev.clearinghouse.net/case/11074/ (last updated 10/27/2025).