Reyes

—Bias Reyes and the Welfare Rights Organization of San Diego, Inc. (Plaintiffs), brought this class action for declaratory and injunctive relief against the San Diego County Board of Supervisors and Department of Social Services (County) to stop the practice of depriving general relief recipients of benefits for failing to comply with work project rules without distinguishing between willful and nonwillful violators and to recover past benefits lost from such illegal terminations. They appeal that portion of the trial court’s order denying its motion for class certification as to retroactive relief. They contend the class for retroactive benefits is ascertainable and meets all proper community of interest requirements necessary for certification, asserting the trial court improperly relied on the County’s potential administrative burdens at the remedy stage of determining class identity and individual claimant entitlements. For the reasons which follow, we conclude the trial court abused its discretion in denying Plaintiffs’ motion for class certification as to retroactive relief. Accordingly, we reverse its order in part.

Factual and Procedural Background

Welfare and…

The court below concluded Metcalf v. Edelman (N.D.I11. 1974) 64 F.R.D. 407 , precludes the class action herein. I do not believe it does so. Moreover, I would read Metcalf not as a confusing expression of law but as being consistent with that federal authority which defines when class certification is proper.

Existing California authority provides a class action is not inappropriate merely because each class member must, at some point, make an individual *1281 showing as to eligibility for recovery or the amount of damages involved. (Employment Development Dept. v. Superior Court (1981) 30 Cal.3d 256, 266 [ 178 Cal.Rptr. 612 , 636 P.2d 575 ].)

Moreover, where there is but one essential issue to be pursued and each claimant’s entitlement to benefits depends upon the existence of this single issue rather than a separate set of issues or facts applicable to him, the class action may go forward. (Hypolite v. Carleson (1975) 52 Cal.App.3d 566, 579-580 [ 125 Cal.Rptr. 221 ] [class defined as those denied benefits because their parents maintained a home together elsewhere]; also see Clothesrigger, Inc. v. GTE Corp. (1987) 191 Cal.App.3d 605, 617 [ 236 Cal.Rptr. 605 ] [class composed of…

Blas Reyes and the Welfare Rights Organization of San Diego, Inc. (Plaintiffs), brought this class action for declaratory and injunctive relief against the San Diego County Board of Supervisors and Department of Social Services (County) to stop the practice of depriving general relief recipients of benefits for failing to comply with work project rules without distinguishing between willful and nonwillful violators and to recover past benefits lost from such illegal terminations. They appeal that portion of the trial court's order denying its motion for class certification as to retroactive relief. They contend the class for retroactive benefits is ascertainable and meets all proper community of interest requirements necessary for certification, asserting the trial court improperly relied on the County's potential administrative burdens at the remedy stage of determining class identity and individual claimant entitlements. For the reasons which follow, we conclude the trial court abused its discretion in denying Plaintiffs' motion for class certification as to retroactive relief. Accordingly, we reverse its order in part.

Welfare and Institutions Code [1]…