Justia Public Benefits Opinion Summaries

Articles Posted in California Courts of Appeal
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With the agreement of her supervisor, Johar, a salesperson, left work for about a week to care for a terminally ill relative. While she was away her employer (SWS) decided she had quit. Upon her return, SWS stated business was slow and gave her no new sales appointments. Johar sought unemployment benefits, citing a “temporary layoff.” SWS denied laying Johar off. While conceding that she left with her supervisor’s approval, SWS claimed that Johar’s failure to provide a return date or otherwise communicate with her supervisor while she was away amounted to a voluntary quit. The Employment Development Department agreed, found Johar ineligible for unemployment benefits, ordered reimbursement of benefits improperly paid, and imposed a penalty for willful misrepresentation. The California Unemployment Insurance Appeals Board (CUIAB) affirmed.After Johar sought judicial review, CUIAB confessed error for failing to consider new evidence discovered by Johar while the administrative appeal was pending. The court dismissed the case without reaching the merits. The court of appeal reversed. Johar was entitled to relief on the existing record. She left her job in emergency circumstances with the employer’s approval, thus for good cause; an employee who leaves work for good cause is presumed to have not voluntarily quit. SWS’ evidence did not establish that Johar positively repudiated her obligation to return in clear terms. View "Johar v. California Unemployment Insurance Appeals Board" on Justia Law

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The Medi-Cal program, California’s enactment of the federal Medicaid program, was administered by the California Department of Health Care Services (the department) administers the Medi-Cal program. In this case, the department sought reimbursement from a revocable inter vivos trust for the Medi-Cal benefits provided on behalf of Joseph Snukst during his lifetime. Following his death, the probate court ordered the assets in the revocable inter vivos trust to be distributed to the sole beneficiary, Shawna Snukst, rather than to the department. The Court of Appeal concluded federal and state law governing revocable inter vivos trusts, as well as public policy, required that the department be reimbursed from the trust before any distribution to its beneficiary. Judgment was therefore reversed and remanded. View "Riverside County Public Guardian v. Snukst" on Justia Law

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Plaintiff Family Health Centers of San Diego operated a federally qualified health center (FQHC) that provided various medical services to its patients, some of whom are Medi-Cal beneficiaries. Section 330 of the Public Health Service Act authorized grants to be made to FQHC’s. In addition, FQHC’s could seek reimbursement under Medi-Cal for certain expenses, including reasonable costs directly or indirectly related to patient care. Plaintiff appealed a trial court’s order denying its petition for writ of mandate seeking to compel the State Department of Health Care Services (DHCS) to reimburse plaintiff for money it expended for outreach services. The Court of Appeal rejected plaintiff’s contention that the trial court and the DHCS improperly construed and applied applicable guidelines in the Centers for Medicare & Medicaid Services Publication 15-1, The Provider Reimbursement Manual (PRM). The Court concluded that the monies spent by plaintiff were not an allowable cost because they were akin to advertising to increase patient utilization of plaintiff’s services. View "Family Health Centers of S.D. v. State Dept. of Health Care Services" on Justia Law

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A.B., a 40-year-old male diagnosed to suffer from severe schizophrenia, has been subject to conservatorships on and off for 20 years. A.B. has no real property or significant assets; his only income is $973.40 in monthly social security benefits. The public guardian was most recently appointed as A.B.’s conservator in 2016 and reappointed annually until the dismissal of the conservatorship in 2019. In August 2017, the public guardian was awarded $1,025 and county counsel was awarded $365 in compensation for services rendered 2016-2017. In 2018, the court entered an order for compensation for the public guardian and county counsel in the same amounts covering 2017-2018. The public guardian sought compensation for services rendered 2018-2019, $1,569.79 for its services, and $365 for county counsel.The court found that the request for compensation was just, reasonable, and necessary to sustain the support and maintenance of the conservatee, and approved the petition, again ordering the public guardian to defer collection of payment if it determined that collection would impose a financial hardship on the conservatee. The court of appeal reversed. While the court had sufficient information before it to enable consideration of the factors enumerated in Probate Code section 2942(b), the court failed to do so and improperly delegated responsibility to the public guardian to defer collection. View "Conservatorship of A.B." on Justia Law

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Appellant N.A. was a nonminor former dependent (NFD). While a minor, she lived with a legal guardian, who received financial aid (aid to families with dependent children-foster care, or AFDC-FC) on N.A.’s behalf. When N.A. was 17 years old, she moved out of the guardian’s home. The San Diego County Health and Human Services Agency was not informed of this circumstance, and AFDC-FC payments to the guardian continued past N.A.’s 18th birthday. The guardian provided some financial support to N.A. after she moved out, but at some point, the guardian stopped providing support altogether. Thereafter, N.A. petitioned to return to juvenile court jurisdiction and foster care, which would provide her with certain services and financial aid, under Welfare & Institutions Code section 388.1. At that time, the Agency became aware of N.A.’s prior living circumstance and determined that she and the guardian became ineligible for AFDC-FC payments when N.A. moved out of the guardian’s home before N.A. turned 18. The Agency sent notice of its decision to the guardian. Based on its determination that N.A. was not actually eligible to receive AFDC-FC payments after she turned 18, the Agency recommended denying her petition for reentry. The juvenile court denied N.A.’s petition for reentry, but ordered the Agency to notify N.A. directly of its eligibility determination so that she could pursue administrative remedies. On appeal, N.A. contended the juvenile court’s order was based on an erroneous interpretation of section 388.1 and related statutes. Alternatively, N.A. argued that the court should have decided the AFDC-FC eligibility issue because exhausting the administrative hearing process would be futile under the circumstances. Finding no reversible error, the Court of Appeal affirmed the order. View "In re N.A." on Justia Law

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The Court of Appeal reversed the superior court's decision reversing the ALJ's finding that A.V. met the statutory criteria for developmental disability: he had a qualifying condition of autism, i.e., ASD; his ASD was substantially disabling; and the condition originated before age 18. The ALJ rejected the Regional Center's argument that a qualifying condition must not only originate but must also become "substantially disabling" before age 18. Although the superior court agreed with the ALJ's decision to the extent it found a claimant's qualifying condition need not become substantially disabling before age 18, it found that the ALJ erred by weighing the parties' evidence "on an even playing field" rather than deferring to the Regional Center's opinions about A.V.'s eligibility for services under the Lanterman Developmental Disabilities Services Act.The court concluded that the superior court erred when it deferred to the Regional Center's eligibility determinations. The court explained that a fair hearing under the Act is just that – an even playing field on which the participants present their evidence to an impartial hearing officer. In this case, the superior court owed deference not to the Regional Center's evaluators but to the administrative process created to fairly resolve disputes over eligibility for services. Accordingly, the court directed the superior court to review the petition under the appropriate standard on remand. View "Tri-Counties Ass'n v. Ventura County Public Guardian" on Justia Law

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Rush retired in 2012. The California State Teachers Retirement System (CalSTRS) calculated his pension as 92.58 percent of his final compensation. Rush disputed the determination of his “final compensation,” defined as “the highest average annual compensation earnable by a member during any period of 12 consecutive months” For 12 consecutive months over portions of two school years, Rush served as an associate dean at a salary significantly higher than his salary during the other portions of those years.CalSTRS applied Education Code section 22115(d): If a member worked at least 90 percent of a school year at the higher pay rate, compensation earnable was to be calculated as if the member earned all service credit for the year at the higher rate. If the member worked less than 90 percent of the year at the higher rate, as Rush did, compensation earnable “shall be the quotient obtained when creditable compensation paid in that year is divided by the service credit for that year.” The court of appeal upheld CalSTRS’s calculation as within the range of reasonable statutory construction. View "Rush v. State Teachers' Retirement System" on Justia Law

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Plaintiffs filed suit alleging discrimination under Government Code section 11135 based on a requirement that all San Diego County applicants eligible for the state's CalWORKs (welfare) program participate in a home visit. The County demurred, arguing there was no discriminatory effect on of the program, no disparate impact caused by the home visits, and the parties lacked standing to sue. The superior court granted the demurrer without leave to amend, and entered judgment. Plaintiffs argued on appeal that their complaint stated a viable cause of action. The Court of Appeal disagreed, finding the complaint did not allege a disparate impact on a protected group of individuals and could not be amended to do so. Therefore, the Court affirmed the superior court. View "Villafana v. County of San Diego" on Justia Law

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The Court of Appeal held that a DSS regulation, Manual of Policies and Procedures (MPP) section 63-603, which addresses replacement issuances of benefits (formerly known as food stamps) under California's CalFresh program, was lawfully adopted and does not conflict with any state or federal statute, and that its plain language requires county welfare departments (CWDs) to replace CalFresh benefits lost through electronic theft (provided a replacement request is made within 10 days of the loss). In this case, MPP 63-603 was within the scope of authority conferred by enabling statutes, and Welfare and Institutions Code section 10072 does not affect the court's analysis. Therefore, the trial court erred by denying plaintiffs' petition for writ of mandate. The court reversed the trail court's judgment and remanded for the trial court to grant the petition. View "Ortega v. Johnson" on Justia Law

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Four consolidated appeals presented a question of whether medical providers who provided services under California’s Medi-Cal program were entitled to reimbursement for the costs of providing in-house medical services for their own employees through “nonqualifying” self-insurance programs. Even for nonqualifying self-insurance programs, however, the Provider Reimbursement Manual allowed providers to claim reimbursement for reasonable costs on a “claim-paid” basis. Oak Valley Hospital District (Oak Valley) and Ridgecrest Regional Hospital (Ridgecrest) had self-insurance programs providing health benefits to their employees. Claims for in-house medical services to their employees were included in cost reports submitted to the State Department of Health Care Services (DHS). DHS allowed the costs when Oak Valley and Ridgecrest employees received medical services from outside providers but denied costs when the medical services were provided in-house. DHS determined claims paid to Oak Valley and Ridgecrest out of their self-insurance plan for in-house medical services rendered to their employees were not allowable costs. The trial court granted Oak Valley and Ridgecrest's the writ petitions on grounds that costs of in-house medical services were reimbursable so long as they were “ ‘reasonable’ ” as defined by the Provider Reimbursement Manual. DHS appealed in each case. After review, the Court of Appeal concluded Oak Valley’s and Ridgecrest’s self-insurance programs did not meet the requirements of a qualified plan under CMS guidelines and Provider Reimbursement Manual. The Court of Appeal rejected DHS’s contention that Oak Valley and Ridgecrest costs relating to in-house medical services for their employees were inherently unreasonable. To the extent DHS argued the cost reports were not per se unreasonable, but unreasonable under the circumstances of the actual treatments of Oak Valley and Ridgecrest employees, the Court determined the evidence in the record supports the trial court’s findings that expert testimony established Oak Valley and Ridgecrest incurred actual expenses in providing in-house medical services for their employees that were not otherwise reimbursed. Accordingly, the Court affirmed the trial court’s granting of the petitions for writs of administrative mandate. View "Oak Valley Hospital Dist. v. Cal. Dept. of Health Care Services" on Justia Law