Justia California Court of Appeals Opinion Summaries

A mother sought child support from the father for their adult son, who has autism and receives government aid. The mother argued that the father, who earns a substantial income, should contribute to their son's support. The father contended that the son's receipt of government aid under the State Supplementary Program for Aged, Blind, and Disabled (SSP) relieved him of any financial responsibility under Family Code section 3910, which mandates parental support for adult children who are incapacitated and without sufficient means.The Superior Court of Los Angeles County ruled in favor of the father, interpreting Welfare and Institutions Code section 12350 to mean that the receipt of government aid barred the mother from seeking child support from the father. The court also limited the attorney’s fees awarded to the mother, reasoning that the case presented a narrow legal issue that did not justify extensive litigation costs.The California Court of Appeal, Second Appellate District, Division One, reversed the lower court's decision. The appellate court held that Welfare and Institutions Code section 12350 only prevents government entities from seeking reimbursement from relatives for the cost of aid provided to recipients. It does not bar a parent from seeking child support from the other parent under Family Code section 3910. The court emphasized that the legislative intent behind these statutes was to prevent the public from bearing the financial burden of supporting individuals who have relatives capable of providing support.The appellate court remanded the case for further proceedings to determine the appropriate amount of child support and to reconsider the attorney’s fees award in light of its ruling. The court clarified that the family court must now address whether the son is incapacitated from earning a living and without sufficient means, and if so, determine the appropriate support amount. View "Marriage of Cady & Gamick" on Justia Law

Nancy Vargas, a bus driver for the Santa Barbara Metropolitan Transit District, injured her foot at work in March 2018. She settled her workers' compensation claim with the district in December 2020, agreeing that the injury caused a 26 percent permanent disability. Vargas also applied for subsequent injury benefits from the Subsequent Injuries Benefits Trust Fund (Fund), listing pre-existing disabilities and disclosing that she was receiving Social Security Disability Insurance (SSDI) payments.The Workers’ Compensation Appeals Board (Board) joined the Fund as a defendant in Vargas’s case. The Fund acknowledged Vargas’s eligibility for benefits but sought a credit for a portion of her SSDI payments, arguing that these payments were for her pre-existing disabilities. The workers’ compensation judge (WCJ) found that the Fund had not proven its entitlement to the credit. The Board upheld this decision, stating that the Fund failed to show that the SSDI payments were awarded for Vargas’s pre-existing disabilities.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the Board’s decision, holding that the Fund bears the burden of proving its entitlement to a credit for SSDI payments under Labor Code section 4753. The court found that the Fund did not provide sufficient evidence to establish that Vargas’s SSDI payments were for her pre-existing disabilities. The court emphasized that the Fund must prove the extent to which SSDI payments are attributable to pre-existing disabilities to reduce subsequent injury benefits. The court also noted that the Fund had ample opportunity to gather evidence but failed to do so. The Board’s order denying the Fund’s petition for reconsideration was affirmed. View "Subsequent Injuries Benefits Trust Fund v. Workers' Compensation Appeals Board" on Justia Law

John Doe, a recipient of vocational rehabilitation services from the California Department of Rehabilitation, sought to have his rent covered while attending a law school outside commuting distance from his home. The Department agreed to cover his tuition and other expenses but refused to pay his rent, classifying it as a non-covered "long-term everyday living expense." Doe argued that rent should be considered "maintenance" under the Rehabilitation Act of 1973 and related California law, which the Department disputed.An administrative law judge (ALJ) upheld the Department's decision, interpreting the law to allow rent as "maintenance" only for short-term shelter, not for the three-year duration Doe required. The Superior Court of Orange County denied Doe's petition for a writ of mandate, agreeing with the ALJ that three years of rent did not qualify as "short-term shelter."The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court found that the term "maintenance" under the Rehabilitation Act and California law includes costs incurred in excess of normal expenses while receiving vocational rehabilitation services, without distinguishing between short-term and long-term costs. The court held that the Department's categorical refusal to cover long-term rent as "maintenance" was incorrect. The court reversed the lower court's decision and remanded the case, directing the Department to reconsider Doe's request for rental assistance based on his individual circumstances, rather than a blanket policy against long-term expenses. View "Doe v. Dept. of Rehabilitation" on Justia Law

James Morell, a retired research attorney for the Orange County Superior Court, was entitled to a pension under the County Employees Retirement Law of 1937 (CERL). The dispute arose over whether the $3,500 Optional Benefit Program (OBP) payments he received should be included in the calculation of his pension. The OBP allowed attorneys to allocate the $3,500 benefit to various options, including taxable cash or a healthcare reimbursement account. Morell allocated portions of the OBP to both cash and healthcare reimbursement in the years leading up to his retirement.The Superior Court of Los Angeles County initially ruled in favor of Morell, ordering the Board of Retirement for the Orange County Employees’ Retirement System (OCERS) to reconsider its decision excluding the OBP payments from Morell’s pension calculation. The court found that the board had improperly relied on a settlement agreement and a repealed statute, Government Code section 31460.1, which had excluded such payments from the definition of "compensation."The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that Resolution 90-1551, adopted by the Orange County Board of Supervisors, which excluded OBP payments from the definition of "compensation," remained valid despite the repeal of section 31460.1. The court found that Morell had elected to participate in the OBP by allocating the $3,500 benefit, and these payments reflected amounts that exceeded his salary. Therefore, the exclusion of the OBP payments from the pension calculation was proper.The Court of Appeal reversed the trial court’s judgment and remanded the case with directions to deny Morell’s petition. The court held that Resolution 90-1551 was still valid and that the OBP payments were correctly excluded from Morell’s pension calculation. View "Morell v. Board of Retirement for the Orange County Employees’ Retirement System" on Justia Law

Nancy Vargas, a bus driver for the Santa Barbara Metropolitan Transit District, injured her foot at work in March 2018. She settled her claim against the district in December 2020, with a stipulated permanent disability of 26 percent. Vargas applied for subsequent injury benefits from the Subsequent Injuries Benefits Trust Fund (Fund), listing pre-existing disabilities and disclosing that she was receiving Social Security Disability Insurance (SSDI) payments. The Fund acknowledged her eligibility but sought to reduce her benefits by the amount of her SSDI payments, claiming these were for her pre-existing disabilities.The Workers’ Compensation Appeals Board (Board) determined that the Fund was not entitled to this reduction, as the Fund had not proven that Vargas’s SSDI payments were awarded for her pre-existing disabilities. The Board found that the evidence provided, including an award letter from the Social Security Administration, did not specify the basis of the SSDI benefits. The Fund’s petition for reconsideration was denied by the Board, which maintained that the Fund needed to show the SSDI payments were for pre-existing disabilities to claim a reduction.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the Board’s decision, holding that the Fund bears the burden of proving its entitlement to a reduction in benefits under section 4753 of the Labor Code. The court found that the Fund did not provide sufficient evidence to establish that Vargas’s SSDI payments were for her pre-existing disabilities. The court emphasized that the Fund must meet its burden of proof by a preponderance of the evidence and that the stipulated disability rating in Vargas’s settlement with her employer did not automatically entitle the Fund to a reduction in benefits. The Board’s order denying the Fund’s petition for reconsideration was affirmed. View "Subsequent Injuries Benefits Trust Fund v. Workers Comp. App. Bd." on Justia Law

James Morell, a retired research attorney for the Orange County Superior Court, was entitled to a pension under the County Employees Retirement Law of 1937 (CERL). The dispute arose over whether the $3,500 Optional Benefit Program (OBP) payments he received should be included in the calculation of his pension. The OBP allowed attorneys to allocate the $3,500 to various benefits or receive it as taxable cash. Morell allocated portions to a healthcare reimbursement account and cash. The Orange County Employees’ Retirement System (OCERS) excluded these payments from his pension calculation, leading to prolonged litigation.The Los Angeles County Superior Court initially ruled in favor of Morell, ordering OCERS to reconsider its decision without relying on Resolution 90-1551, which OCERS argued required the exclusion of OBP payments. The court found that the resolution had been invalidated and that Morell could not waive his argument that OCERS’ calculation contravened CERL through a settlement agreement.The California Court of Appeal, Second Appellate District, Division One, reviewed the case. The court concluded that Resolution 90-1551, which adopted the provisions of the now-repealed Government Code section 31460.1, remained valid due to a savings clause in Senate Bill 193. This clause preserved actions taken by counties under section 31460.1 before its repeal. The court found that Morell had elected to participate in the OBP and that the payments reflected amounts exceeding his salary.The Court of Appeal reversed the trial court’s judgment and remanded the case with directions to deny Morell’s petition. The court held that Resolution 90-1551 was still valid and that OCERS correctly excluded the OBP payments from Morell’s pension calculation. View "Morell v. Board of Retirement of the Orange County Employees' Retirement System" on Justia Law

In the case before the Court of Appeal of the State of California First Appellate District Division Two, the appellant, Debra Abney, challenged the decision of the State Department of Health Care Services and the City and County of San Francisco to consider money garnished from her Social Security payments as income for the purposes of determining her eligibility for benefits under Medi-Cal.Abney's Social Security payments were being reduced by nearly $600 each month to satisfy a debt she owed to the IRS. The authorities considered this garnished money as income, which led to Abney being ineligible to receive Medi-Cal benefits without contributing a share of cost. Abney argued that the money being garnished was not income “actually available to meet her needs” under the regulations implementing the Medi-Cal program.The trial court rejected Abney's argument, and she appealed. The Court of Appeal affirmed the trial court's decision. The Court of Appeal held that the tax garnishment was "actually available" to meet Abney's needs because it benefitted her financially by helping to extinguish her debt to the IRS. Therefore, the garnished money was correctly considered as income for the purpose of calculating her eligibility for the Medi-Cal program. View "Abney v. State Dept. of Health Care Services" on Justia Law

Securus Technologies, LLC (Securus), is one of six telecommunications companies providing incarcerated persons calling services (IPCS) in California. In this original proceeding, Securus challenges the decision of the California Public Utilities Commission (PUC) adopting interim rate relief for IPCS in the first phase of a two-phase rulemaking proceeding. Among other things, the PUC’s decision: (1) found IPCS providers operate as locational monopolies within the incarceration facilities they serve and exercise market power; (2) adopted an interim cap on intrastate IPCS rates of $0.07 per minute for all debit, prepaid, and collect calls; and (3) prohibited providers from charging various ancillary fees associated with intrastate and jurisdictionally mixed IPCS.   The Second Appellate District affirmed the PUC’s decision. The court concluded Securus has not shown the PUC erred by finding providers operate locational monopolies and exercise market power. The court held that facts do not—as Securus contends—demonstrate Securus “cannot recover its costs (including a reasonable rate of return)” under the interim rate cap and do not amount to a “clear showing” that a rate of $0.07 per minute “is so unreasonably low” that “it will threaten Securus’s financial integrity.” Thus, Securus has failed to satisfy its “burden of proving . . . prejudicial error” on constitutional grounds. View "Securus Technologies v. Public Utilities Com." on Justia Law

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

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