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Administrative Law Keyed to Schwartz
Haskell v. Department of Agriculture
Citation:
930 F.2d 816 (1991)Facts
Haskell Brothers Grocery was approved for participation in the food stamp program in 1978. Due to excessive food stamp redemptions, the store was investigated in 1980 and penalized in 1981 for exchanging food stamps for cash and marijuana. Between October 1986 and January 1987, a second investigation revealed that store owners and employees engaged in transactions with an investigative aide in which food stamps were exchanged for cash, marijuana, and other ineligible items. After each visit to the store, the investigative aide and a special agent prepared and signed transaction reports detailing the violations. Based on these reports, the USDA permanently disqualified the store from the food stamp program. Before the administrative determination was finalized, the investigative aide died in an automobile accident. Haskell challenged the admissibility of the transaction reports and claimed his due process rights were violated.
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