Materiality of Omitted Administrative Rulings in Probable Cause Determinations

Introduction

Megan Hedgepeth v. Nash County is an unpublished Fourth Circuit decision addressing the interplay between administrative benefit‐determination proceedings and subsequent criminal‐process actions. At issue was whether Nash County and its employees violated Hedgepeth’s Fourth Amendment rights by obtaining an arrest warrant without disclosing an administrative hearing result that had exonerated her of fraud. Plaintiff–Appellant Megan Hedgepeth had received Supplemental Nutrition Assistance Program (SNAP) benefits through Nash County’s Department of Social Services (DSS). After moving to a different county and omitting her partner, Tawaildo Brown, from her household certification, she faced a fraud investigation, an administrative recertification (resulting in a temporary reduction of benefits), and ultimately arrest. Hedgepeth sued under 42 U.S.C. § 1983, alleging malicious prosecution, abuse of process, and procedural due‐process violations, among other claims. The district court granted summary judgment for the defendants, and the Fourth Circuit affirmed.

Summary of the Judgment

The Fourth Circuit’s per curiam opinion affirmed the district court’s grant of summary judgment in favor of Nash County and its employees. It held:

Malicious Prosecution/Abuse of Process: The warrant application, though omitting the administrative hearing’s outcome, was supported by probable cause. The omitted administrative determination was not “material” to the magistrate’s decision because the evidence actually presented—witness statements, school records, DMV filings—was more than sufficient to establish probable cause of benefit fraud.
Procedural Due Process: Hedgepeth’s benefits were reduced only upon recertification for a new eligibility period, not mid-period, so no hearing was required before the benefit adjustment. Under Holman v. Block, SNAP recipients have no protected entitlement to uninterrupted benefits beyond each certification term.
Other Claims: Race/sex‐discrimination and state‐law tort claims were abandoned or foreclosed by the absence of a constitutional violation.

Analysis

Precedents Cited

English v. Clarke, 90 F.4th 636 (4th Cir. 2024): Warrants are usually conclusive of probable cause absent deliberate or reckless false statements or omissions that materially mislead the magistrate.
Humbert v. Mayor & City Council of Baltimore City, 866 F.3d 546 (4th Cir. 2017): A plaintiff must show that an officer omitted material facts with intent or reckless disregard to mislead in a warrant application.
Thurston v. Frye, 99 F.4th 665, 673 (4th Cir. 2024): Fourth Amendment challenges to warrant‐backed arrests proceed as malicious‐prosecution claims.
Holman v. Block, 823 F.2d 56 (4th Cir. 1987): SNAP recipients have no property interest in continuous benefits beyond each certification period; no pre‐deprivation hearing is required when benefits are adjusted at recertification.
Banks v. Block, 700 F.2d 292 (6th Cir. 1983): Establishes that administrative certification periods define the only entitlement period under the Food Stamp Act.

Legal Reasoning

On the malicious‐prosecution claim, the court applied the “materiality” test from Humbert and English. It first confirmed that the information Webb submitted to the magistrate—independent witness confirmations, DMV and school records, inconsistent post office mailings—was sufficient to establish probable cause of SNAP‐fraud. Then it asked whether inclusion of the hearing officer’s ruling (that the County failed to prove cohabitation and improperly reduced benefits) would negate probable cause. Because none of the new evidence relied on at the hearing was before the magistrate, and the hearing’s outcome said only that evidence presented there was insufficient, the Fourth Circuit held that the omitted administrative ruling was immaterial: the magistrate’s probable‐cause determination stood.

On due process, the court closely read the record to determine that Hedgepeth’s benefits were reduced only when she was recertified for a new six‐month term—not mid‐term. Under Holman and Banks, there is no protected interest in continuation of SNAP benefits beyond the official certification period. As a result, no hearing was required before the new benefit level was set.

Impact

This decision clarifies two important points:

Material Omissions in Warrants: Administrative or civil‐process outcomes need not be disclosed in a warrant application where the evidence supporting probable cause stands on its own. Unless omitted facts are “necessary” to probable cause, a warrant applicant need not relay every prior administrative determination.
SNAP Benefits and Due Process: Applicants cannot claim a continuous entitlement to benefits beyond each certification period. Recertification at a lower rate does not trigger pre‐deprivation process rights so long as the adjustment coincides with the start of a new term.

Complex Concepts Simplified

Malicious Prosecution (Fourth Amendment): A claim that an arrest supported by a warrant lacked probable cause and ended in the plaintiff’s favor.
Probable Cause vs. Materiality: Probable cause means a fair probability or reasonable ground to believe a crime occurred. “Materiality” asks whether omission of certain facts would have prevented a neutral magistrate from finding that probability.
SNAP Certification Period: Under federal law, SNAP benefits are granted for fixed certification periods (up to 12 months). At the end of each period, recipients must reapply; there is no guarantee of automatic renewal at the same level.
Procedural Due Process: The constitutional requirement that the government provide notice and, where necessary, a hearing before depriving someone of a protected life, liberty, or property interest.

Conclusion

Megan Hedgepeth v. Nash County reinforces that:

Warrants supported by abundant independent evidence are not invalidated by omitting prior administrative rulings that do not undercut probable cause.
SNAP recipients’ procedural due process protections do not extend beyond discrete, statutorily defined certification periods.

Together, these holdings guide public‐benefit administrators, fraud investigators, and magistrates on the limits of required disclosures in warrant applications and clarify recipients’ procedural rights in public assistance programs.