Brown v. Crandall
198 Cal. App. 4th 1
| Cal. Ct. App. | 2011Background
- Brown seeks a writ of administrative mandamus to compel the County to find her eligible for residual medical coverage under Welfare & Institutions Code §17000, asserting the County’s failure to evaluate eligibility under its residual coverage standards.
- County denied CMSP benefits on the basis that Brown’s February 2009 income exceeded the CMSP threshold, prompting Brown to challenge eligibility determinations and seek reevaluation under residual coverage standards adopted September 22, 2009.
- Brown’s petition sought not only CMSP relief but also mandamus to compel the County to implement and run a residual coverage program for indigent residents not fully covered by CMSP.
- The trial court sustained the County’s demurrer without leave to amend, concluding Brown lacked standing and was not within the class protected by §17000; Brown amended, and the court again demurred, before appellate reversal.
- The appellate court held Brown has standing to seek a judicial determination of the County’s residual coverage program under the public duty exception, and remanded for further proceedings consistent with its opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brown has standing under §17000 to challenge the County’s residual coverage. | Brown is an indigent resident described by §17000 and seeks reevaluation under residual coverage. | County contends Brown lacks standing as she is not the intended beneficiary or public duty beneficiary. | Brown has standing under the public duty exception and may pursue the writ. |
| Whether Brown is a person described in §17000. | Brown is indigent and unable to afford care, thus within §17000’s class. | Brown’s assets and income show she is not indigent under §17000. | Brown satisfies the §17000 class; questions of indigence are factual and not resolved on demurrer. |
| Whether the public right/public duty exception permits enforcement by a private citizen. | CBrown, as a citizen, seeks enforcement of the County’s public duty to provide subsistence medical care. | Exception should be narrowly applied due to competing public interests. | The public duty exception applies; Brown may seek mandamus to enforce the duty. |
| Whether the demurrer was proper given the adequacy of allegations about public need and standing. | Allegations show a weighty public need and that Brown has a beneficial interest or public right to seek relief. | Demurrer proper because Brown’s petition failed to plead standing and public need. | Demurrer erred; allegations sufficiently invoke standing under the public duty exception. |
| Whether the County’s residual coverage standards, as applied, comply with §17000. | Standards are incomplete and not properly implemented; need reevaluation and clearer processes. | Standards adopted in response to litigation may satisfy §17000; issues of sufficiency are factual for trial. | Remand for full factual development; Court does not decide as a matter of law whether standards satisfy §17000. |
Key Cases Cited
- County of San Diego v. State of California, 15 Cal.4th 68 (Cal. 1997) (§17000 creates residual fund for indigents who cannot qualify for other aid)
- Alford v. County of San Diego, 151 Cal.App.4th 16 (Cal. Ct. App. 2007) (public duty to provide subsistence medical care to working poor; indigence beyond zero income)
- Waste Management of Alameda County, Inc. v. County of Alameda, 79 Cal.App.4th 1223 (Cal. Ct. App. 2000) (standing; beneficial interest requirement for writs of mandamus)
- Green v. Obledo, 29 Cal.3d 126 (Cal. 1981) (public duty exception to mandamus standing; public right enforcement)
- Union of American Physicians & Dentists v. County of Santa Clara, 149 Cal.App.3d 45 (Cal. Ct. App. 1983) (public duty to indigents; standing to enforce)
- Committee on Children’s Television, Inc. v. General Foods Corp., 35 Cal.3d 197 (Cal. 1983) (indigence-related standing; pleading ultimate facts)
- Hunt v. Superior Court, 21 Cal.4th 984 (Cal. 1999) (definition of indigence for public aid eligibility)
- Casters on v. Superior Court, 101 Cal.App.4th 177 (Cal. App. 2002) (standing; demurrer standards)