Legal Opinion

Interpretation of "Federal Means-Tested Public Benefit" in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996

Department of Justice Office of Legal Counsel

Decided December 16, 2025Published

1Opinion of the Court

(Slip Opinion) Interpretation of “Federal Means-Tested Public Benefit” in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 This Office concluded in 1997 that the phrase “Federal means-tested public benefit,” as used in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, could permissibly be read to include only benefits administered under manda- tory (but not discretionary) federal spending programs. We therefore deferred to two agencies’ interpretation under the Chevron framework. Having been asked to recon- sider in view of Loper Bright…

2Cases cited29 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Federal Deposit Insurance v. MeyerSupreme Court of the United States · 1994
  3. Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
  4. Jett v. Dallas Independent School DistrictSupreme Court of the United States · 1989
  5. Quackenbush v. Allstate InsuranceSupreme Court of the United States · 1996

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