Halsey v. Fedcap Rehabilitation Services, Inc., No. 23-1351 (1st Cir. 2024)
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This case involves an appeal from plaintiffs Sara Halsey and Susan Kiralis-Vernon against Fedcap Rehabilitation Services, Inc. The plaintiffs were participants in a state program, Additional Support for People in Retraining and Employment - Temporary Assistance for Needy Families (ASPIRE-TANF), for which Fedcap was a contract agency. The plaintiffs allege that Fedcap failed to correctly administer the program and fulfill its obligations, including informing them of available services and support, processing their requests for benefits, and engaging in an interactive process to evaluate their requests for reasonable accommodations. Kiralis-Vernon also alleges that a Fedcap employee verbally assaulted her due, in part, to her race.
The U.S. District Court for the District of Maine dismissed the case, reasoning that the plaintiffs were required to first pursue an administrative remedy before the Department of Health and Human Services as required by Maine law. On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the claims related to Fedcap’s administration of the ASPIRE-TANF program, agreeing that under Maine law, the plaintiffs had to first seek administrative review before bringing these claims to court.
However, the appellate court vacated the dismissal of Kiralis-Vernon's claim of racial discrimination, ruling that this claim did not fall within the same jurisdiction and expertise of the Department, and thus, was not subject to the same requirement for administrative review. The case was remanded for further proceedings on this claim.
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