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California Department of Human Resources Development v. Java

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Unemployment insurance


Supreme Court of the United States
California Department of Human Resources Development v. Java
Reference: 402 U.S. 121
Term: 1971
Important Dates
Argued: February 24, 1971
Decided: April 26, 1971
Outcome
United States District Court for the Northern District of California affirmed
Majority
Warren BurgerHugo BlackJohn Harlan IIWilliam BrennanPotter StewartByron WhiteThurgood MarshallHarry Blackmun
Concurring
William Douglas

California Department of Human Resources Development v. Java was a case decided on December 5, 1967, by the United States Supreme Court, which ruled that California could not halt joint federal-state unemployment insurance payments to Java after her employer filed an appeal under California Unemployment Insurance Code Section 1335.[1][2]

The Supreme Court affirmed the lower court's decision and held that terminating benefits without a hearing after initial approval of an unemployment claim violated the Social Security Act.[1][2]

Background

Judith Java was fired from her job and was deemed eligible for unemployment insurance benefits after an initial interview with a representative of the state. Benefit payments began immediately but automatically ceased after Java's employer filed an appeal claiming she was fired with cause. Section 1335 of the California Unemployment Insurance Code required unemployment insurance payments to stop until appeals were resolved.[1][2]

Java filed a class action lawsuit in the United States District Court for the Northern District of California, alleging Section 1335 conflicted with Section 303(a)(1) of the Social Security Act. Section 303(a)(1) required states to ensure their administrative structures were "reasonably calculated to insure full payment of unemployment compensation when due." Java argued that benefits were due after the initial interview and could not be interrupted until an appeal hearing determined her ineligible to receive benefits.[1][2]

The district court held that California's administrative procedure denied Java due process since her benefits were terminated without a hearing. The court also held that the denial of benefits following the employer's appeal amounted to a failure to pay Java's benefits when due in violation of Section 303(a)(1). The court ordered California to stop suspending benefits after appeals under Section 1335.[1][2]

Oral argument

Oral argument was held on February 24, 1971. The case was decided on April 26, 1971.[1]

Decision

The Supreme Court decided 9-0 that Section 1335 of the California Unemployment Insurance Code conflicted with the Social Security Act and was unconstitutional under the Supremacy Clause. Chief Justice Warren Burger, joined by Justices Hugo Black, John Harlan II, William Brennan, Potter Stewart, Byron White, Thurgood Marshall, and Harry Blackmun. Justice William Douglas delivered a concurring opinion.[3][1]

Opinions

Opinion of the court

Justice Warren Burger, writing for the court, found that Section 1335 of the California Unemployment Insurance Code conflicted with the Section 303(a)(1) of the Social Security Act and was unconstitutional under the Supremacy Clause. Burger said compensation under the Social Security Act was due after the initial eligibility determination:[1]

We agree with the conclusion of the District Court that § 1335 of the California Unemployment Insurance Code conflicts with the requirements of § 303(a)(1) of the Social Security Act. This holding makes it unnecessary to reach the constitutional issue involved in Goldberg v. Kelly, supra, on which the District Court relied.[4]
—Justice Warren Burger, majority opinion in California Department of Human Resources Development v. Java[1]

See also

External links

Footnotes

  1. 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 Justia, "California Dept. of Human Resources v. Java, 402 U.S. 121 (1971)," accessed November 8, 2021
  2. 2.0 2.1 2.2 2.3 2.4 Cornell Law School, "CALIFORNIA DEPARTMENT OF HUMAN RESOURCES DEVELOPMENT et al., Appellants, v. Judith JAVA et al.," accessed November 17, 2021
  3. Cite error: Invalid <ref> tag; no text was provided for refs named oyez
  4. Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.