Contra Costa County Children & Family Services Bureau v. R.G.
240 Cal. App. 4th 1090
| Cal. Ct. App. | 2015Background
- R.G., a nonminor dependent under California’s AB 12 (Fostering Connections/extended foster care), sought continued foster care payments for Jan 13–Mar 13, 2015.
- After turning 18, R.G. elected extended foster care, had a TILP updated Jan 13, 2015 emphasizing job search and full‑time employment as goals.
- Between Jan and Mar 2015 R.G. actively searched for work (20–30+ applications, in‑person visits, interviews), received resume coaching from an independent living specialist, and kept contact with his social worker.
- At the Feb hearing the court expressed doubt that job‑search activity alone satisfied eligibility under Welf. & Inst. Code § 11403(b)(3) and set a termination hearing; R.G. obtained full‑time work March 11, 2015.
- The juvenile court reinstated R.G. prospectively but denied retroactive AB 12 payments for the Jan–Mar period, concluding participation in online/self‑directed job searches was insufficient under § 11403(b)(3).
- The Court of Appeal reversed, holding the juvenile court misinterpreted § 11403(b)(3) and that R.G.’s documented, self‑directed job‑search activities met the statute and relevant guidance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §11403(b)(3) requires formal program enrollment to qualify as "participating in a program or activity designed to promote, or remove barriers to employment." | R.G.: documented self‑directed job search and TILP activities satisfy (b)(3) and warrant retroactive benefits. | Bureau/juvenile court: (b)(3) requires an organized program or more than informal job applications; lack of 80 hrs/month during period weighs against eligibility. | Court of Appeal: (b)(3) covers organized programs or other activities; self‑directed job searches and TILP‑documented efforts satisfy (b)(3); reversal for retroactive benefits. |
Key Cases Cited
- In re K.L., 210 Cal.App.4th 632 (summarizes AB 12 framework and nonminor dependent eligibility categories)
- In re M.C., 199 Cal.App.4th 784 (statutory interpretation principles; consider plain meaning and legislative purpose)
- In re A.F., 219 Cal.App.4th 51 (standard of review and emphasis on supporting former foster youth independence)
- In re Aaron S., 235 Cal.App.4th 507 (affirming denial where minimal, unsupported work‑search claims lacked verification)
- In re Nadia G., 216 Cal.App.4th 1110 (deference to juvenile court credibility findings where participation evidence was suspect)