Alford v. County of San Diego

Case No. D048758 (Cal. Ct. App. May 23, 2007); Clearinghouse Number: 55896

Description

California Court of Appeal Holds That San Diego County May Not Deny Access To Health Care Based On An Inflexible Income Cap That Does Not Take Into Account Ability To Pay, Citing In Particular The Denial of Health Care To The Working Poor

Abstract

A California Court of Appeal held that San Diego County violated the state Welfare and Institution Code by basing eligibility for indigent health care on an inflexible income cap without regard to ability to pay. Petitioners had filed a class action suit seeking injunctive and declaratory relief against San Diego County and alleging that county denies medically necessary care to a low-income resident whose countable monthly income exceeds a standard maintenance need level without considering the applicant's ability to pay. Citing California precedent, petitioners asserted that decades of case law support their position that county must take care of the medically needy. Respondents are state and county officials who govern and administer the county medical services program. One petitioner was diagnosed with lymphoma and hospitalized for ten days after receiving emergency room treatment. County denied her medical benefits application because her countable income exceeded the $802 standard maintenance need level for individuals. A second petitioner was hospitalized and underwent emergency surgery for a collapsed lung. County later sent notice denying his application for county medical benefits. Petitioners alleged that respondents' actions caused irreparable injury for which petitioners have no adequate remedy at law because they do not have the means to obtain basic health care to preserve life unless the court grants equitable relief. Petitioners alleged an actual and present controversy regarding the duties of respondents under the state welfare code. Petitioners sought an order directing county to adopt new eligibility standards that allow free or reduced-cost care to uninsured indigent residents. The county did adopt new eligibility standards which the Court of Appeal found unlawful.

Additional Information

Attorney Information
Plaintiffs and Appellants represented by Richard Rothschild, Catherine Murphy, Western Center on Law and Poverty, 3701 Wilshire Blvd., Suite 208, Los Angeles, CA 90010 (213.487.7211).
Docket Date
2007-05-23 05:00:00+00:00
Attorney Email
rrothschild@wclp.org