Alleged Intervention by Legal Assistance Group Into Implementation of Food Stamp Workfare Pilot Project

GAO was asked to investigate an incident of alleged intervention by a legal assistance group into the implementation of a food stamp workfare pilot project. It was also asked to determine whether such action constituted an illegal expenditure of federal funds. A city filed an application to participate in a workfare demonstration project with the Department of Agriculture. A resolution was introduced for consideration by the city's board of aldermen that would authorize the city to implement and expend funds for the project. While the resolution was under consideration, a legal assistance group, which was a Legal Services Corporation grantee, wrote a letter to the aldermen noting potential problems with the workfare project and requesting that it defeat the resolution. Statutory restrictions which are most applicable to the action of the legal assistance group are the restriction on the use of federal funds to interfere with the implementations of the provisions of the Food Stamp Act and restrictions on the use of Legal Services Corporation grant funds by recipients to undertake to influence the passage or defeat of legislation by Congress or by any state or local legislative bodies. In the Food Stamp Act, Congress was seeking to insure that federal funds would not be used to support illegal activities designed to make implementation of projects such as workfare more difficult. Congress did not intend to preclude organizations, with the use of federal funds, from exercising their first amendment rights and making their views known to legislative bodies. The act of the legal assistance group should not be interpreted as interfering with or impeding the implementation of the project by the board of aldermen; thus, the group did not violate the restriction on the use of federal funds to interfere with the implementation of Food Stamp Act provisions. The Legal Services Corporation Act requires the Corporation to ensure that funds made available to grantees are not used directly or indirectly to influence the passage of legislation by Congress or state or local legislative bodies. The legal assistance group's act violated the provisions of this act since comments were not requested by the aldermen, and the letter did not concern a matter directly affecting the activities of their organization. Federal funds were expended illegally for the preparation and distribution of the letter.