Angie Christensen, Plaintiff and Respondent v. Will Lightbourne, as Director

Summary

The court upheld the Department of Social Services’ determination that funds garnished from a household member’s wages or unemployment benefits to pay court-ordered child support are included in the paying household’s income when calculating CalWORKs eligibility and benefits. It concluded that the Department’s interpretation was a reasonable exercise of delegated lawmaking authority and that counting the funds in the paying household did not violate the statutory prohibition against considering one recipient’s income or resources in determining another recipient’s aid. The court also rejected the argument that the funds were not reasonably anticipated to be received because the relevant statutory inquiry concerns the timing and certainty of income, not its ultimate availability to the household.