Hunt v. Superior Court

Citation987 P.2d 705,90 Cal.Rptr.2d 236,21 Cal.4th 984
CourtUnited States State Supreme Court (California)
Decision Date22 November 1999
PartiesJim HUNT, as Director, etc., et al., Petitioners, v. The SUPERIOR COURT of Sacramento County, Respondent; Mary Guimbellot et al., Real Parties in Interest.

L.B. Elam and Robert A. Ryan, Jr., County Counsel, and Michele Bach, Deputy County Counsel, for Petitioners.

John J. Sansone, County Counsel (San Diego), Diane Bardsley, Chief Deputy County Counsel, and Stephen R. Magruder, Deputy County Counsel, for County of San Diego as Amicus Curiae on behalf of Petitioners.

Kathleen Bales-Lange, County Counsel (Tulare) and Teresa Saucedo, Deputy County Counsel, for County of Tulare as Amicus Curiae on behalf of Petitioners.

No appearance for Respondent.

Northern California Lawyers for Civil Justice, Eugenie Denise Mitchell, Sacramento; Western Center on Law and Poverty, Richard A. Rothschild, Los Angeles, Robert D. Newman, Brooklyn, N.Y., Melinda R. Bird, Los Angeles; Legal Services of Northern California, Curtis L. Child and Karen A. Wells, Sacramento, for Real Parties in Interest.

Catherine I. Hanson, San Francisco; Astrid Meghrigian, San Francisco; Lois Richardson; Remcho, Johansen & Purcell, Robin B. Johansen, Joseph Remcho, San Francisco, and Philip C. Monrad, Oakland, for California Medical Association and California Association of Hospitals and Health Systems as Amici Curiae on behalf of Real Parties in Interest.

Catherine L. Fisk, Los Angeles, for California Law Professors as Amicus Curiae on behalf of Real Parties in Interest.

GEORGE, C.J.

The Legislature authorizes counties to calculate general assistance grants for indigent residents pursuant to a formula based upon the "federal official poverty line." (Welf. & Inst.Code, § 17000.5, subd. (a).)1 It also permits a county to deduct from these cash grants the value of "in-kind aid" provided by the county, such as food, shelter, and up to $40 per month of medical care. (Ibid.) Sacramento County (hereafter the County) determined that it could satisfy its statutory obligation to provide medical care to indigent residents solely by providing the general assistance standard of aid specified in section 17000.5. Thus, it limited eligibility for county medical care to those residents financially eligible for general assistance. The County also decided that it could cease providing medical care even to residents eligible for general assistance, if it chose not to deduct $40 per month of the value of medical care from general assistance grants. The trial court entered a preliminary injunction precluding the County from implementing this eligibility standard for medical care, or any other standard that fails to consider a resident's financial ability to pay the actual costs of obtaining subsistence medical care. The Court of Appeal, however, agreed with the County's position and directed the trial court to dissolve the injunction.

We conclude that the trial court properly enjoined the County's implementation of these eligibility standards for receiving medical care. Section 17000 — not section 17000.5 — prescribes the extent of a county's obligation to provide medical care to its residents, and existing law establishes that the duty to provide medical care pursuant to section 17000 extends beyond the class of residents financially eligible for general assistance. Further, if there were any doubt regarding the correct interpretation of section 17000.5 with respect to a county's ongoing obligation to provide health care, the point has been clarified explicitly by the Legislature's recent declaration that, contrary to the Court of Appeal's determination, the general assistance standard of aid calculated pursuant to section 17000.5 is not intended to satisfy, in whole or in part, a county's duty to provide health care services under section 17000. (§ 17000.51.) Instead, as the trial court concluded, in determining eligibility for subsistence medical care pursuant to section 17000, counties must consider a resident's financial ability to pay the actual costs of obtaining such care. Accordingly, the judgment of the Court of Appeal is reversed.

I
A The Statutory Framework

Section 17000 imposes upon counties a mandatory duty to "relieve and support all incompetent, poor, indigent persons, and those incapacitated by age, disease, or accident," when those persons are not relieved and supported by some other means.2 (Mooney v. Pickett (1971) 4 Cal.3d 669, 676, 94 Cal.Rptr. 279, 483 P.2d 1231.) In the last several decades many specialized relief programs have been enacted to support indigent individuals, but section 17000 "creates `the residual fund' to sustain indigents `who cannot qualify ... under any specialized aid programs.' [Citations.]" (County of San Diego v. State of California (1997) 15 Cal.4th 68, 92, 61 Cal.Rptr.2d 134, 931 P.2d 312, italics added by the court in County of San Diego (County of San Diego ).) This statute imposes upon counties a duty to provide medical care to indigent persons not eligible for such care under other programs. (Id. at pp. 92-94, 100-104, 61 Cal.Rptr.2d 134, 931 P.2d 312.)

Section 17001 requires each county to "adopt standards of aid and care for the indigent and dependent poor."3 Although this provision confers upon a county broad discretion to determine eligibility for — and the types of — indigent relief, this discretion must be exercised in a manner that is consistent with — and that furthers the objectives of — state statutes. (County of San Diego, supra, 15 Cal.4th at p. 100, 61 Cal.Rptr.2d 134, 931 P.2d 312; Mooney v. Pickett, supra, 4 Cal.3d at pp. 678-681, 94 Cal.Rptr. 279, 483 P.2d 1231.) These objectives are "to provide for protection, care, and assistance to the people of the state in need thereof, ... to promote the welfare and happiness of all of the people of the state by providing appropriate aid and services to all of its needy and distressed," and to administer such aid and services "promptly and humanely." (§ 10000.) Furthermore, "[t]he provisions of law relating to a public assistance program shall be fairly and equitably construed to effect the stated objects and purposes of the program." (§ 11000.) "County standards that fail to carry out section 17000's objectives `are void and no protestations that they are merely an exercise of administrative discretion can sanctify them.' [Citation.] Courts, which have `"final responsibility for the interpretation of the law,"' must strike them down. [Citation.] Indeed, despite the counties' statutory discretion, `courts have consistently invalidated ... county welfare regulations that fail to meet statutory requirements. [Citations.]' [Citation.]" (County of San Diego, supra, 15 Cal.4th at p. 100, 61 Cal. Rptr.2d 134, 931 P.2d 312.)

To ensure that general assistance programs meet statutory requirements, a line of Court of Appeal decisions beginning with Boehm v. County of Merced (1985) 163 Cal.App.3d 447, 452-453, 209 Cal.Rptr. 530, held that each county must conduct a specific factual study of its residents' actual subsistence cost of living before setting the amount of general assistance grants. (Whitfield v. Board of Supervisors (1991) 227 Cal.App.3d 451, 457-461, 277 Cal.Rptr. 815; Guidotti v. County of Yolo (1989) 214 Cal.App.3d 1552, 1562-1563, 271 Cal.Rptr. 858; Poverty Resistance Center v. Hart (1989) 213 Cal.App.3d 295, 304-305, 271 Cal.Rptr. 214; Boehm v. Superior Court (1986) 178 Cal.App.3d 494, 501-502, 223 Cal.Rptr. 716.) In 1991, however, the Legislature specified a minimum general assistance grant that it deems to be "a sufficient standard of aid." (§ 17000.5, subd. (b).) As originally enacted, section 17000.5, subdivision (a), stated in relevant part: "The board of supervisors in any county may adopt a general assistance standard of aid that is 62 percent of a guideline that is equal to the 1991 federal official poverty line," and that may be adjusted annually by the amount of any adjustment provided under the Aid to Families with Dependent Children (AFDC) program.4 (Stats.1991, ch. 91, § 34, p. 488.) By eliminating the requirement that counties undertake Boehm studies to determine the actual amount needed for minimum subsistence, the statute provided a safe harbor for counties choosing to adopt this standard of aid. (Bell v. Board of Supervisors (1994) 23 Cal. App.4th 1695, 1703-1705, 28 Cal.Rptr.2d 919; Oberlander v. County of Contra Costa (1992) 11 Cal.App.4th 535, 542, 15 Cal.Rptr.2d 182.)

A 1992 amendment to section 17000.5, subdivision (a), clarified that the value of noncash benefits provided by the county may be included in the general assistance standard of aid. The amended subdivision stated in pertinent part: "[A]ny county may adopt a general assistance standard of aid, including the value of in-kind aid, that is 62 percent of a guideline that is equal to the 1991 federal official poverty line...." (Stats.1992, ch. 722, § 139, p. 3498, italics added.) Thus, a county may satisfy its statutory obligation to support and relieve the indigent by providing in-kind aid such as food and shelter, and may reduce general assistance grant levels by the value of in-kind aid that is actually made available. (Bell v. Board of Supervisors, supra, 23 Cal.App.4th at pp. 1705-1710, 28 Cal.Rptr.2d 919; Oberlander v. County of Contra Costa, supra, 11 Cal.App.4th at pp. 545-546, 15 Cal. Rptr.2d 182; see also Robbins v. Superior Court (1985) 38 Cal.3d 199, 210 & fns. 15, 16, 211 Cal.Rptr. 398, 695 P.2d 695 [indicating, before the enactment of section 17000.5, that some forms of in-kind aid could be included in general assistance benefits].)

The issue whether the term "in-kind aid" as used in section 17000.5 includes medical care was considered in Gardner v. County of Los Angeles (1995) 34 Cal. App.4th 200, 40 Cal.Rptr.2d 271. In Gardner, the superior court had denied a motion for a preliminary injunction seeking to preclude the county from reducing its general...

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