Constance Savage v. Lorraine M. Aronson

Summary

The Supreme Court of Connecticut upheld the trial court's jurisdiction over a class challenge by AFDC recipients to a 100-day-per-year limit on emergency housing benefits, rejecting objections based on housing-docket assignment, sovereign immunity, and failure to exhaust administrative remedies. On the merits, it held that the limit does not conflict with General Statutes §§ 17-85, 17-82d, or 17-38a (a), because the relevant statutory language imposes eligibility conditions and appropriation-based ceilings rather than mandating emergency housing until permanent homes are found. It further held that neither the federal constitutional protection of family integrity nor the state constitutional right to education was violated, since the plaintiffs' hardship stemmed from financial circumstances rather than state action and the education right guarantees equal enjoyment, not schooling at any particular school. The judgment was set aside and the court directed judgment for the commissioner; Glass J., dissenting, would have read § 17-82d (a)'s 'as is needed' language to invalidate the 100-day limit and would have remanded for narrower relief involving the housing and human resources agencies.