Christensen v. Lightbourne

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The Supreme Court held that the determination of the California Department of Social Services (the Department) that a household member's income that is used to pay child support for a child living in another household counts as income "reasonably anticipated" to be "received" by the paying household within the meaning of Cal. Welf. & Inst. Code 11265.2 for the purposes of determining eligibility for state welfare benefits was reasonable and therefore valid. Plaintiff applied for California Work Opportunity and Responsibility to Kids (CalWORKs) aid to support herself and her family. The Director of the Department denied the claim, concluding that child support payments garnished from Plaintiff's husband's earned income and unemployment insurance benefits was correctly included as nonexempt available income in determining eligibility for CalWORKs benefits. The superior court declared the department's policy of counting court-ordered child support payments as available income of CalWORKs applicants invalid. The court of appeal reversed. The Supreme Court affirmed, holding that the Department’s determination that funds garnished to pay child support for the benefit of a child living in another household are not exempt from the paying household’s income for purposes of determining its eligibility for or amount of CalWORKs aid was a reasonable exercise of its lawmaking authority and was therefore valid. View "Christensen v. Lightbourne" on Justia Law