County of Sacramento v. State of California

In this appeal from a judgment holding the state and various state officials (state) liable to the County of Sacramento (county) for the county’s unreimbursed expenditures in administering a state-mandated program of “in-home supportive services” for aged, blind and disabled persons, we are called upon to decide the state’s responsibility for funding the program. We hold that the state met its total funding obligation by exceeding the “matching” contribution required to secure federal dollars and that it was not further obligated to reimburse the county for administrative expenses.

Facts

On January 1, 1974, the federal government consolidated its adult income maintenance programs for aged, blind and disabled persons and reorganized their funding. ( Pub.L. No. 92-603. ) To qualify for federal funds, California enacted legislation for supplemental payments and services for aged, blind and disabled Californians. (Welf. & Inst. Code, § 12000 et seq., added by Stats. 1973, ch. 1216, § 37, p. 2904.) A program was created providing for in-home “supportive services,” which include “domestic services, heavy cleaning, nonmedical personal services, accompaniment . .. during…