Chaudhary v. Department of Human Services

Illinois Supreme Court
Civil Court
Administrative Agency Law
Citation
Case Number: 
2023 IL 127712
Decision Date: 
Friday, January 20, 2023
Holding: 
Appellate court judgment affirmed, circuit court judgment affirmed, department decision reversed.
Justice: 
NEVILLE

Illinois Supreme Court considered which party has the burden of proof in an action where the Department of Human Services seeks to recover an alleged overpayment of SNAP benefits. The court ruled in favor of the recipient beneficiary, finding that because the statute was silent on the burden of proof the “default rule” applied and stated that the party bringing the action had the burden of proof. The Supreme Court concluded that the Department initiated the action when it determined that an overpayment had been made and that it had the burden of proof throughout the proceedings. (THEIS, OVERSTREET, HOLDER WHITE and CUNNINGHAM, concurring. ROCHFORD and O’BRIEN took no part in the decision)