Bear River Band of Rohnerville Rancheria v. California Department of Social Services

CourtDistrict Court, N.D. California
DecidedMarch 11, 2024
Docket4:23-cv-01809
StatusUnknown

This text of Bear River Band of Rohnerville Rancheria v. California Department of Social Services (Bear River Band of Rohnerville Rancheria v. California Department of Social Services) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bear River Band of Rohnerville Rancheria v. California Department of Social Services, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 BEAR RIVER BAND OF ROHNERVILLE Case No. 23-cv-01809-HSG RANCHERIA, et al., 8 ORDER GRANTING IN PART AND Plaintiffs, DENYING IN PART DEFENDANTS’ 9 MOTIONS TO DISMISS AND v. GRANTING DEFENDANTS’ 10 REQUESTS FOR JUDICIAL NOTICE CALIFORNIA DEPARTMENT OF 11 SOCIAL SERVICES, et al., Re: Dkt. Nos. 32, 38

12 Defendants.

13 14 Pending before the Court are Defendants’ motions to dismiss and requests for judicial 15 notice. Dkt. Nos. 32, 38. For the reasons described below, the Court GRANTS IN PART and 16 DENIES IN PART Defendants’ motions, and GRANTS Defendants’ requests for judicial notice. 17 I. BACKGROUND 18 On March 13, 2023, Plaintiffs Madison Fisher and Bear River Band of Rohnerville 19 Rancheria Tribe (“the Tribe”) filed a lawsuit in Humboldt County Superior Court against the 20 California Department of Social Services (“CDSS”), CDSS Director Kim Johnson, Humboldt 21 County Department of Health and Human Services (“HDHHS”), and HDHHS Director Connie 22 Beck (collectively, “Defendants”). Dkt. No. 1-1. One month later, CDSS removed the case to 23 federal court, asserting federal question jurisdiction, see Dkt. No. 1, and on August 14, 2023, 24 Plaintiffs filed a First Amended Complaint (“FAC”). Dkt. No. 23. 25 Plaintiffs’ claims arise out of Defendants’ administration of the extended foster care 26 program as applied to Native youth in the Tribe. As relevant here, the Federal Foster Care 27 Program helps to provide out-of-home care for children until they are safely returned home, placed 1 FAC ¶ 17. It also entitles states, territories, and tribes to claim partial federal reimbursement for 2 the cost of providing this care to children who meet federal eligibility criteria. Id. A child’s 3 eligibility for foster care is determined by the criteria established pursuant to the Aid to Families 4 with Dependent Children program (“AFDC”). Although the Temporary Assistance for Needy 5 Families (“TANF”) welfare program eventually replaced AFDC, eligibility for the Federal Foster 6 Care Program is still linked to the eligibility requirements of the AFDC (i.e., “AFDC linkage”). 7 Id. ¶ 18. The provision of partial federal reimbursement for foster care under Title IV-E of the 8 Social Security Act is contingent on an AFDC linkage being made, which requires an initial 9 income and resource evaluation for all participants. Id. ¶ 19, 23. Determinations of the child’s 10 continued eligibility for federal Title IV-E foster care benefits are conducted periodically, but the 11 AFDC linkage requirement is only required once per foster care episode. So long as the youth 12 remains in foster care, no redeterminations of the AFDC linkage are required to demonstrate 13 federal Title IV-E eligibility. FAC ¶ 24. 14 This case concerns the redetermination of AFDC linkages for Native youth over 18 15 continuing in the foster care system. As part of the Fostering Connections to Success and 16 Increasing Adoptions Act of 2008 (P.L. 110-351), Congress amended the Title IV-E program to 17 provide states and tribes an option to extend eligibility for federal foster care to youth between the 18 ages of 18 and 21 (i.e., nonminor dependents (“NMDs”)). FAC ¶ 25. California opted into the 19 extended foster care program in 2010. Id. ¶ 28. That same year, the U.S. Department of Health 20 and Human Services announced that redeterminations of AFDC linkage would not be required for 21 NMDs who continued in extended foster care upon reaching the age of 18. Id. ¶ 26. In other 22 words, “[i]f a nonminor dependent was receiving federal or nonfederal foster care prior to age 18 23 and continued to be in foster care after his/her 18th birthday, the nonminor dependent continues to 24 be eligible for federal or nonfederal foster care without a new eligibility determination.” Id. ¶ 29. 25 Pursuant to this federal guidance, CDSS issued All County Letter (“ACL”) 11-10 on 26 January 28, 2011 confirming that annual redeterminations of AFDC linkage were not required for 27 nonminors who continued in foster care upon reaching the age of 18. Id. ¶ 30. In response to 1 2013, providing guidance on the applicability of the extended foster care laws for Native youth. 2 See Dkt. No. 33-1 at 4. Plaintiffs take issue with one sentence in the seven-page ACL: “For 3 purposes of maintaining Title IV-E funding, Indian youth must still meet the financial Aid to 4 Families with Dependent Children-Foster Care (AFDC-FC) eligibility requirements as all other 5 NMDs to receive the AFDC-FC payment.” FAC ¶ 32 (emphasis added). Plaintiffs allege that 6 because this guidance did not distinguish between the requirements for youth continuing in foster 7 care as opposed to those re-entering foster care, it implied that all Native NMDs were subject to 8 redeterminations. As a result, Plaintiffs maintain that “CDSS, Humboldt County, and Humboldt 9 DHHS regularly conducted redeterminations of eligibility on non-minor youth of the Tribe 10 entering the 18 and Over Program even though they had never left the foster care program.” Id. ¶ 11 33. This practice allegedly had a “significant and disproportionate impact on American Indian 12 youth” because Defendants allegedly considered the “tribally based financial distributions” that 13 could become available to some Indian youth upon reaching the age of majority to be a 14 disqualifying resource when conducting redeterminations. Id. ¶ 36. Plaintiffs further allege that 15 Humboldt County’s policy or custom was to “dissuade Tribal youth from applying for the 18 and 16 Over Program in the first place based on the County’s misguided belief that all American Indian 17 youth receive tribal distributions and the incorrect conclusion that those individuals would need to 18 undergo eligibility redeterminations.” Id. This policy or custom allegedly deprived Tribal youth 19 of benefits that they would have been entitled to receive through extended foster care absent 20 CDSS’s improper practice of conducting redeterminations and dissuading youth from applying. 21 In June 2021, the California Tribal Families Coalition send a letter to CDSS warning that 22 ACL 13-91 had “led county agencies to overly monitor tribal youth in extended foster [care] for 23 eligibility,” and asked CDSS to rescind and correct the letter and redress any wrongful loss of 24 benefits that Indian youth might have experienced. FAC ¶ 40. On February 15, 2022, CDSS 25 issued ACL 22-16 “remind[ing] foster care placing agencies of the eligibility and redetermination 26 rules for federal foster care from ACL 11-10,” and reiterating that “[f]or youth who turn 18 while 27 under an order for foster care placement, no redetermination shall be conducted solely due to the 1 13-91, and because Defendants have undertaken only “nominal efforts” to re-enroll eligible Indian 2 youth and have taken “no steps” to “redress the harm suffered by American Indian youth who 3 have unlawfully lost years of benefits to which they were entitled,” the harm has not abated. Id. ¶¶ 4 45–47. Moreover, Plaintiffs allege that the County “has continued its policy or custom of finding 5 non-minor American Indian youth . . . ineligible for the 18 and Over Program as a result of tribal 6 ‘per capita distributions.’” Id. ¶ 48. They allege that Plaintiff Madison Fisher was one such 7 youth. According to Plaintiffs, Fisher applied for extended foster care benefits when she turned 8 18, and was originally approved. However, a few months after moving into a house arranged by 9 Humboldt County, the County “changed its mind unilaterally and stripped Plaintiff Fisher of her 10 eligibility for the 18 and Over Program due to her receipt of tribal distributions, which was 11 disclosed at the time of application.” Id. ¶ 57.

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Bear River Band of Rohnerville Rancheria v. California Department of Social Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bear-river-band-of-rohnerville-rancheria-v-california-department-of-social-cand-2024.