Gautam v. Perales

Petitioner, a single male adult, originally commenced this CPLR article 78 proceeding against the New York City Human Resources Administration alleging that his Home Relief *510grant ($215 per month) pursuant to 18 NYCRR part 352 was "insufficient to meet [his] reasonable housing costs” and sought an increase by way of judicial relief. After joinder of the Commissioner of the State Department of Social Services ("DSS”) as a proper party, and in particular reliance upon Jiggetts v Grinker (75 NY2d 411), the IAS court concluded that the effect of Jiggetts was to limit the Commissioner’s…