Sneed v. Saenz

Decision Date27 July 2004
Docket NumberNo. D041472.,D041472.
PartiesLidia SNEED et al., Plaintiffs and Appellants, v. Rita SAENZ, as Director, etc., et al., Defendants and Respondents.
CourtCalifornia Court of Appeals Court of Appeals

Sheppard, Mullin, Richter & Hampton, Edward D. Vogel, Karin Dougan Vogel, San Diego; San Diego Volunteer Lawyer Program, Rosemary Bishop, San Diego; Coalition of California Welfare Rights Organizations and Grace Gallagher, Sacramento for Plaintiffs and Appellants.

Bill Lockyer, Attorney General, Andrea Hoch, Chief Assistant Attorney General, James Humes, Assistant Attorney General, John H. Sanders and Jennifer A. Chmura, Deputy Attorneys General, for Defendants and Respondents.


Plaintiffs Lidia Sneed and Cheryl Bell appeal a judgment in favor of defendants California Department of Social Services and its Director, Rita Saenz, (together Department) after the court denied Sneed and Bell's petitions for ordinary and administrative mandamus and request for declaratory relief. In those proceedings, Sneed and Bell challenged Department's interpretation and implementation of the maximum family grant (MFG) statute (Welf. & Inst.Code,1 § 11450.04) as applied to their families' ability to receive welfare cash assistance under the California Work Opportunity and Responsibility to Kids Act (CalWORKs) program (Stats.1997 ch. 270, § 50).

In essence, the MFG statute denies an increase in the maximum aid cash payment, a dollar amount that ordinarily correlates with family size, if additional children are born to a family that has been on welfare for the previous 10 months. (§ 11450.04, subd. (a).) Sneed and Bell contend the court should have granted mandamus and declaratory relief because Department's regulations interpreting the MFG statute sanction families like theirs, who have additional children while on welfare but who also have nonwelfare income to support these additional children. Specifically, they assert Department's flawed interpretation of the MFG statute: (1) is inconsistent with the statute's plain language, statutory context and the stated purpose of California's welfare program; (2) greatly expands the scope of the penalty of the MFG statute; and (3) incorrectly reduces the cash grant for many poor families with their own nonwelfare income.

The MFG statute also provides that "child support" must be paid to the family and is not considered deductible income in calculating the amount of the cash grant. (§ 11450.04, subd. (e).) Department's regulations include as "child support" a noncustodial parent's Social Security benefits paid on behalf of a child. Bell contends Department violated federal law by deducting her children's Social Security benefits from the family's cash grant without considering the children's needs. Bell and Sneed further contend Department's interpretation of "child support" as support only from a noncustodial parent violates their constitutional rights to privacy and equal protection.

We conclude Department correctly interpreted and implemented the MFG statute with respect to the welfare cash assistance to which Sneed and Bell were entitled. Adequate support for all of the needy children of California's working poor is a matter of priority; indeed, California spent most of the last decade experimenting with welfare reform under a series of federal Aid to Families with Dependent Children (AFDC) program waivers to try to break the cycle of welfare dependency and ensure economic security and self-sufficiency for California families. The culmination of California's efforts was the passage in 1997 of comprehensive welfare reform, including the creation and implementation of the CalWORKs program. We find nothing in the language of the applicable statutes, properly interpreted, nor any indicia of legislative intent, suggesting cash aid grants to families with MFG children are to be calculated under CalWORKs using the methodology employed under the repealed AFDC program. The California Legislature has addressed the cash assistance needs of California's working poor families — and done so in the context of welfare reform designed to insure the long term economic viability of the family unit. Any claim that the calculation of the cash aid component of public assistance denies California's MFG children adequate support must be directed to that body, not this court. Accordingly, we affirm the judgment.2


For many years, the federal AFDC program provided cash assistance to poor families. (42 U.S.C. § 601, as in effect before Aug. 22, 1996; see California Homeless & Housing Coalition v. Anderson (1995) 31 Cal.App.4th 450, 453, 37 Cal.Rptr.2d 639.) States could not impose eligibility requirements or calculate welfare grants in a manner inconsistent with AFDC without risking loss of federal funding. (42 U.S.C. § 601.) To implement "experimental" provisions, states were required to seek federal waivers. (42 U.S.C. § 1315(a).)

When California began welfare reform efforts in 1991, the AFDC grant structure arguably was a disincentive to increasing the amount of a welfare recipient's income from work-related activities. The grant calculation methodology required subtracting the maximum aid payment (MAP), as provided in section 11450, subdivision (a), from the minimum basic standard of adequate care (MBSAC), an amount used to establish a family's eligibility for welfare benefits. Under AFDC, the MBSAC and MAP amounts were federally mandated and were the same dollar amount for families composed of an equal number of needy individuals. Under the AFDC cash grant calculation methodology, as family income increased, the welfare cash grant decreased dollar for dollar.3

In 1991 California created a work incentive for welfare recipients of AFDC, under federal waiver, by increasing the difference between the MBSAC and MAP each year between 1991 and 1997. This allowed families to keep more of their earnings before their welfare cash grant declined. Under the federal waiver, still in effect in 1994 when the MFG statute was enacted, the grant was the difference between (1) the MAP and (2) the MBSAC minus nonexempt or disregarded income.4

In 1994 the Legislature enacted section 11450.04, the MFG statute, which was intended to promote personal responsibility of welfare recipients by discouraging growth in family size while they received public assistance and by encouraging them, through work incentives, to support their families and thereby eliminate their dependence on welfare. The MFG statute freezes a family's maximum welfare cash benefit at the same level if additional children (referred to as MFG children) are born to a family that has been on welfare for the previous 10 months.5 Thus, under the MFG statute, the MAP, a dollar amount that ordinarily increases with family size, does not increase when an MFG child is born. (§ 11450.04, subd. (a).) Although MFG children are not included in the assistance unit6 for purposes of determining the MAP they are aid recipients for all other purposes.7 The MFG statute refers to the MAP dollar amounts as set forth in section 11450, subdivision (a).

The MFG statute further provides that 100 percent of any child support payment received for an MFG child shall be paid to the assistance unit. The child support payment is not considered deductible income to the family for purposes of calculating the amount of cash aid for which the family is eligible. (§ 11450.04, subd. (e).)

In 1996 Congress enacted the Personal Responsibility and Work Opportunity Reconciliation Act, commonly known as the Welfare Reform Act. (Pub.L. No. 104-193 (Aug. 22, 1996) 110 Stat. 2105; see also Arenas v. San Diego County Bd. of Supervisors (2001) 93 Cal.App.4th 210, 213, 112 Cal.Rptr.2d 845 (Arenas).) Under the Welfare Reform Act, a program entitled Temporary Aid to Needy Families (TANF) provided states with block funding to distribute to needy families as each state saw fit. (Arenas, at p. 213, 112 Cal.Rptr.2d 845; 42 U.S.C. § 601 et seq.) TANF replaced the federally funded AFDC program. (Arenas, at p. 213, 112 Cal.Rptr.2d 845.) Under TANF, eligible state plans must limit the receipt of aid to a specified number of months and must include certain elements such as requiring aid recipients to engage in specified work activities. (42 U.S.C. §§ 607, 608.) Additionally, TANF requires the state to provide services relating to establishing or enforcing child support obligations with respect to each child receiving assistance. (42 U.S.C. § 654.)

In 1997, as part of a comprehensive review and overhaul of its welfare system, California created CalWORKs through which it administers TANF block grants. (Stats.1997, ch. 270, § 50; Legis. Counsel's Dig., Assem. Bill No. 1542 (1997-1998 Reg. Sess.); Welf. & Inst.Code, § 11200 et seq.; Arenas, supra, 93 Cal.App.4th at p. 213, 112 Cal.Rptr.2d 845.) Department is charged with administering CalWORKs. (§ 11209; see also Fry v. Saenz (2002) 98 Cal.App.4th 256, 260, 120 Cal.Rptr.2d 30.) Like the former AFDC program, CalWORKs provides cash grants to families with minor children who meet certain requirements, including limited income and resources, and are deprived of the support of one or both parents due to factors such as absence, disability or unemployment. (§ 11250, subds.(a)-(c); Sheyko v. Saenz (2003) 112 Cal.App.4th 675, 682, 5 Cal. Rptr.3d 350.) The Legislature stated the purposes of CalWORKs as follows:

"The Legislature finds and declares that the family unit is of fundamental importance to society in nurturing its members, passing on values, averting potential social problems, and providing the secure structure in which citizens live out their lives. Each family unit has the right and responsibility to provide for its own economic security by full participation in the work force to the extent possible. Each family has the right and responsibility to provide sufficient support and...

To continue reading

Request your trial
16 cases
  • Christensen v. Lightbourne, S245395
    • United States
    • United States State Supreme Court (California)
    • July 8, 2019
    ...(AFDC) program provided cash aid to needy families. ( 42 U.S.C. § 601, as in effect before Aug. 22, 1996; Sneed v. Saenz (2004) 120 Cal.App.4th 1220, 1229, 16 Cal.Rptr.3d 563 ( Sneed ).) "The AFDC program [wa]s one of three major categorical public assistance programs established by the Soc......
  • In re Mary G.
    • United States
    • California Court of Appeals
    • May 24, 2007
    ... ... [Citations.] TANF replaced the federally funded AFDC program." ( Sneed v. Saenz (2004) 120 Cal.App.4th 1220, 1231, 16 Cal. Rptr.3d 563.) "A state's participation in the TANF program is voluntary, but if a state chooses ... ...
  • Christensen v. Lightbourne
    • United States
    • United States State Supreme Court (California)
    • July 8, 2019
    ...(AFDC) program provided cash aid to needy families. ( 42 U.S.C. § 601, as in effect before Aug. 22, 1996; Sneed v. Saenz (2004) 120 Cal.App.4th 1220, 1229, 16 Cal.Rptr.3d 563 ( Sneed ).) "The AFDC program [wa]s one of three major categorical public assistance programs established by the Soc......
  • Hendrick v. N.H. Dep't of Health & Human Servs.
    • United States
    • Supreme Court of New Hampshire
    • August 2, 2016
    ...and identifying its purpose and intended effects ...." Crosby, 530 U.S. at 373, 120 S.Ct. 2288.Relying primarily upon Sneed v. Saenz, 120 Cal.App.4th 1220, 16 Cal.Rptr.3d 563, 577–80 (2004), a case interpreting Title II of the Social Security Act, DHHS argues that the requirement that SSI i......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT