Lamb

County of San Diego (County) paid benefits under the Aid to Families with Dependent Children (AFDC) program to Catherine Lamb’s minor daughter, Sarah, after Sarah left Catherine’s home and had a baby. Catherine appeals from a judgment ordering her to pay County $3,377 in retroactive child support to reimburse County for part of those benefits. Catherine contends the court erred in ordering her to reimburse County because, among other things, the AFDC reimbursement statute (Welf. & Inst. Code, § 11350) provides for recoupment of AFDC benefits only from the “noncustodial parent” of the aided child—in this case, the father of Sarah’s baby. We agree and reverse the judgment.

Factual and Procedural Background

Catherine is the mother of Sarah, who was bom in June 1978. In June 1993, Sarah apparently left home over Catherine’s objections and refused to return. In March 1994, when she was 15 years old, Sarah gave birth to a son, Alexander, allegedly fathered by David Torres. That same month, Sarah began receiving AFDC benefits from County. In October 1994, County filed a complaint against Catherine under section 11350, seeking to recoup those benefits through an order of…