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HomeMy WebLinkAboutMINUTES - 07291986 - 2.2 2.2 THE BOARD OF SUPERVISORS OF CONTRA COSTA "COUNTY, CALIFORNIA Adopted this Order on July 29 , 1986 , by the following vote: AYES: Supervisors Fanden, Schroder, McPeak, Torlakson, Powers NOES: None ABSENT: None ABSTAIN: None -------------------------------------------------------------------- -------------------------------------------------------------------- SUBJECT: Decision on Appeal of Linda Smith The Board on July 15 , 1986 , closed the hearing on the appeal of Linda Smith, 1701 Mahogany Way, #35 , Antioch, CA 945092 from the administrative decision of the Appeals and Complaints Division of the Social Service Department, and deferred decision to July 29 , 1986 . County Counsel was requested to review the issue of whether the Social Security survivor' s benefits of Ms. Smith' s 17 .year-old son, Michael, may be considered available for the support of his mother with whom he lives in determining her eligibility to receive General Assistance. In a July 25 , 1986 , report to the Board, County Counsel, advised that the minor child' s survivors benefits could not be con- sidered to be available for the support of the mother in determining her eligibility to receive General Assistance. County Counsel recommended that the Board grant the appeal of Ms. Smith. IT IS BY THE BOARD ORDERED that the appeal of Linda Smith is GRANTED. IT IS FURTHER ORDERED that the Social Service Director is INSTRUCTED to reconsider Ms. Smith' s application for General Assistance benefits in accordance with the views expressed in County Counsel' s report (copy attached and included as part of this document) . hereby cPrtIfy that Wks I:?.sy .­of an action taE;en and entered on the, i°e Board of Supervisors on the dale lshomi. ATTESTED: pp��pp a /. � q � Hha Board of Supervisoas and County Ad''6rA1113tr8'k0F cc: Ms. Linda Smith Contra Costa Legal Services Foundation Attn: Steven R. Berg Social Service Department Appeals & Complaints Division County Counsel County Administrator COUNTY COUNSEL'S OFFICE REC_-,qIVED CONTRA COSTA COUNTY MARTINEZ, CALIFORNIA J U L 2, 5 1986 Date: July 25, 1986 BATC�JELO-7g ERY CO PH!LRD OF SUPERVISORS 6 RA COS iA C To: Board of Supervisors De From: Victor J. Westman, County Counsel By: Paul R. MunizS Deputy County Counsel I Re: General Assistance Appeal of Linda Smith County # 07-92-358352-3BB2 RECOMMENDATION: We recommend that the Board of Supervisors grant the appeal of Linda Smith. Her application for General Assistance should be reconsidered without including her son Michael within the GA Budget Unit. DISCUSSION: The sole issue presented in this appeal is whether the Social Security sur- vivor's benefits of a 17-year-old minor may be considered available for the sup- port of the mother, with whom he lives, in determining her eligibility to receive General Assistance. The Standards for Administration of the General Assistance Program (Bd. Res. 85/505) and the Social Service Department Manual provide that the income of a defined "GA Budget Unit" is used to determine an individual applicant's eligi- bility for General Assistance. (Standards, SSI.C, II.D; DM 49-401, SS II.3, IIA, III.A.) Appellant's 17-year-old son, Michael, receives Social Security survivor's benefits in the amount of $586 per month (42 U.S.C. S402(d)). Appellant is the representative payee of her son's benefits, apparently because of his minority (42 U.S.C. S405(j)(1); 20 C.F.R. S404.2010(b)) . As representative payee, appellant "has a responsibility to...[u]se the payments...she receives only for the use and benefit of [her son] ... ." (20 C.F.R. S404.2035(a).) "If the current maintenance needs of [her son] are met, [appellant] may use part of the payments for the support of [her son's] legally dependent spouse, child, and/or parent." (20 C.F.R. 5404.2040(c), emphasis added.) Payments in excess of the needs of her son and the support of his legal dependents "shall be conserved or invested on behalf of [her son] ." (20 C.F.R. S404.2045(a).) Whether appellant may apply any of her son's benefits to her own support, and thus whether the County may charge her with applying them to her own sup- port, depends on whether she is "legally dependent" upon her son, that is, whether her son has a legal duty to support her. This is a question of state law. Board of Supervisors July 25, 1986 Civil Code section 206 requires that adult children of a person in need who is unable to maintain himself by work maintain that person to the extent of their ability. (In re Jerald C. (1984) 36 Cal.3d 1, 5 [201 Cal.Rptr. 342, 678 P.2d 9171; Swoap v. Superior Court (1973) 10 Cal.3d 490, 502-507 [111 Cal.Rptr. 136, 516 P.2d 8401 ; Garcia v. Superior Court (1941) 45 Cal.App.2d 31, 33 [113 P.2d 4701; see Civ. Code, §206.5, Pen. Code, §270c.) There is no such duty on the part of minor children to support their needy parents. CONCLUSION: Appellant Linda Smith is not legally dependent upon her son Michael so long as he remains under 18 years of age. Michael's Social Security survivor's bene- fits may not, therefore, presently be applied to the support of appellant, nor may the County deem those benefits to be available for her support at this time. Michael should not be considered to be part of the GA Budget Unit (see DM 49-401, §III.A.l.b), and appellant's application for General Assistance should be reconsidered on that basis. If she is found .to be eligible for General Assistance, the fact that she shares housing with Michael must nevertheless be considered in determining the housing component of her grant. (DM 49-207, §III; 49-402, §II.D.) PRM:Is -2-