Case Explained: ICARE CHILD DEVELOPMENT CENTER LLC LAUREN DAVIS v. ALETHEA CICERO-BROWN Georgia Department of Early Care and Learning Legal Services Officer

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-11 Docket: 1:24-cv-02291-SEG The eleventh-circuit affirmed the district court’s denial of a preliminary injunction that would have reinstated iCare Child Development Center LLC into Georgia’s childcare voucher program. The court held that while the provider might possess a property interest in continued participation, it was not constitutionally entitled to a pre-deprivation hearing under the Due Process Clause of the Fourteenth Amendment before being dismissed for failing to cooperate with an on-site investigation. In reaching this conclusion, the court applied the three-factor balancing test established in *Mathews v. Eldridge*, weighing the private interest affected, the risk of erroneous deprivation, and the government’s interest. The court determined that a provider’s interest in the voucher program is less significant than interests protected in cases involving welfare or disability benefits because dismissal does not strip the provider of its license to operate generally or prevent revenue from non-program clients. Furthermore, the court found the risk of erroneous deprivation negligible given that the dismissal turned on an objective “yes-or-no” question regarding the failure to provide required records, a fact the provider conceded. Finally, the court emphasized the government’s significant interest in promptly removing non-compliant providers to ensure child safety and conserve public resources, noting that requiring pre-deprivation hearings would impose undue administrative burdens. As a practical consequence, the denial of the preliminary injunction stands, meaning iCare remains dismissed from the voucher program without immediate reinstatement pending further proceedings. The provider is not entitled to an evidentiary hearing prior to its removal from the program based on the specific failure to comply with investigation record requests. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.