Appeal from the District Court of Williams County, Northwest Judicial District, the Honorable David W. Nelson, Judge.
The opinion of the court was delivered by: Crothers, Justice.
N.D. Supreme CourtEnnis v. N.D. Dep't of Human Services, 2012 ND 185
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Opinion of the Court by Crothers, Justice.
Ennis v. N.D. Dep't of Human ServicesNo. 20110352
[¶1] The North Dakota Department of Human Services ("the Department") appealed from a district court judgment reversing the Department's order determining Edward Ennis was ineligible for continued Supplemental Nutrition Assistance Program ("SNAP") benefits. Ennis cross-appealed, challenging the district court's denial of his motion for costs. We reverse the judgment and reinstate the Department's final order denying further benefits.
[¶2] Ennis is self-employed. Since 2008, he has received food stamps, now designated as SNAP benefits, through Williams County Social Services ("the County"). Each year, the County recertified Ennis's eligibility for continued benefits by projecting his anticipated income for the upcoming year based upon his income as shown on his tax return for the prior year. In calculating Ennis's income for the prior year, the County deducted expenses Ennis incurred in producing that income.
[¶3] In April 2010, Ennis purchased a truck for $5,238 for use in his business. He paid for the truck in full and thus did not make ongoing payments. In March 2011, the County conducted a periodic recertification review to determine Ennis's continued eligibility for SNAP benefits. The County calculated his anticipated 2011 self-employment income based upon his actual 2010 self-employment income, without deducting the $5,238 expense for the truck. Based on this calculation, the County determined Ennis's anticipated 2011 income exceeded the income limit for SNAP benefits and issued a denial of benefits.
[¶4] Ennis appealed to the Department and requested a hearing. An administrative law judge ("ALJ") issued recommended findings of fact, conclusions of law and order determining that the purchase price of the truck should have been deducted from Ennis's anticipated 2011 self-employment income and recommending that the County's denial of further benefits be reversed. The executive director of the Department disagreed with the ALJ's recommendation and issued amended findings, conclusions and final order affirming the County's determination that Ennis was not entitled to further SNAP benefits. Ennis appealed to the district court, which reversed the Department's final order and reinstated the recommended findings of the ALJ.
[¶5] The Department appealed, arguing it appropriately determined Ennis's one-time, nonrecurring expenditure to purchase the truck in 2010 should not be deducted when calculating his anticipated self-employment income for 2011. Ennis cross-appealed, arguing the district ...