Christensen v. Lightbourne
A144254
| Cal. Ct. App. | Oct 6, 2017Background
- Angie Christensen applied for CalWORKs; her household included her, her three children, and her husband Bruce, who paid court-ordered child support for three children who lived outside the household.
- San Mateo County treated the amounts garnished from Bruce’s wages and unemployment benefits for those outside-children as nonexempt income to Christensen’s assistance unit and denied CalWORKs cash aid as income exceeded the maximum aid payment.
- The Department of Social Services had a longstanding policy (ACL No. 97-59) treating child support paid for children outside a payer’s assistance unit as countable income; a prior MPP regulation allowing a deduction was repealed after CalWORKs implementation.
- An administrative law judge favored Christensen, but the Department Director issued an alternate decision upholding the county’s calculation; Christensen petitioned for writ of administrative mandate and declaratory relief.
- The trial court granted the writ and declaratory relief, concluding the Department’s policy conflicted with MPP §44-101(a) (“reasonably anticipated…available to needy members”) and §11005.5 (avoiding double counting).
- The Court of Appeal reversed: it deferred to the Department’s consistent interpretation, rejected Christensen’s “availability” and double-counting arguments, and held garnished child support need not be exempted from payer’s household income for CalWORKs eligibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court-ordered child support garnished from a payer who lives in the CalWORKs assistance unit but benefits children outside the unit must be exempted from the payer’s household income when computing CalWORKs eligibility | Christensen: Garnished support is not "available to needy members of the family" under MPP §44-101(a) and so should be excluded; counting it leads to impermissible double counting under §11005.5 | Department: No statute or regulation requires exempting such support; "reasonably anticipated" income refers to gross prospective income and all anticipated income is "available" per MPP §44-102.1; longstanding ACL properly treats garnishments as nonexempt income | Court: Reversed trial court; deferred to Department’s interpretation and held garnished child support may be counted as nonexempt income to the payer’s assistance unit; no statutory or regulatory requirement to exempt it |
| Whether counting the garnished child support violates §11005.5 by "double counting" income between different assistance units | Christensen: The same funds are counted in both payer’s and recipient child’s aid calculations, violating §11005.5’s prohibition on treating one recipient’s aid or income as available to another | Department: Child support paid for a child in a CalWORKs family is typically assigned to the county, distributed to government entities, and (except limited pass-throughs) is not treated as income to that recipient family; here, no double counting occurred | Court: Rejected double-counting claim; Rogers v. Dietrich inapplicable because garnished child support is not CalWORKs "aid," and record did not show the child’s unit received the garnished amounts as income |
Key Cases Cited
- Sneed v. Saenz, 120 Cal. App. 4th 1220 (discussion of CalWORKs purpose and grant structure)
- Yamaha Corp. of America v. State Bd. of Equalization, 19 Cal. 4th 1 (framework for deference to agency interpretations)
- Larkin v. W.C.A.B., 62 Cal. 4th 152 (agency interpretations not given effect if clearly erroneous or unauthorized)
- Heckler v. Turner, 470 U.S. 184 (rejecting “actual availability” rule for excluding mandatory payroll withholdings from income)
- Rogers v. Dietrich, 58 Cal. App. 3d 90 (prohibiting treating one recipient’s aid or income as available to another under §11005.5)