Smith v. Los Angeles County Board of Supervisors

Plaintiffs challenge a pilot program in Los Angeles County that makes a home visit a condition of eligibility for CalWORKs benefits. They contend the county has created an unauthorized condition; the pilot project violates the requirements for early fraud prevention and detection programs; the home searches conducted pursuant to the program violate state and federal constitutional requirements for welfare-related home searches or administrative searches; the policy imposes unconstitutional conditions on the receipt of welfare benefits; and it violates the right to privacy guaranteed by article I, section 1 of the California Constitution.

We find neither a constitutional violation nor a conflict between the home visit pilot program and the CalWORKs statutory and regulatory scheme. We affirm the judgment.

Factual and Procedural Summary

“In 1996, the federal government enacted what is known as the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 42 United States Code (U.S.C.) section 602 et seq., which authorized funding to states for welfare-to-work programs. PRWORA replaced two federally funded welfare programs, Aid to Families with…