Meder v. City and County of San Francisco, Human Service Agency
- William Orrick
- 3:20-cv-01200
- U.S. District Court · Northern District of California
- 4
In Meder v. City and County of San Francisco, Human Service Agency, Judge Orrick recommended dismissal after finding federal jurisdiction barred by state-court review rules.
Elen Meder and Walter Meder, who sought federal review of the denial of their locally funded CAAP benefits; the City and County of San Francisco Human Service Agency was the defendant.
What happened
In Meder v. City and County of San Francisco, Human Service Agency, Elen Meder and Walter Meder sought federal review after San Francisco denied them County Adult Assistance Programs benefits based on their residency status. They argued that they were permanently residing in the United States under a federal regulation.
The court granted their application to proceed without paying filing fees but screened the complaint and found no federal jurisdiction. It concluded that the requested relief would overturn or effectively appeal decisions by the San Francisco County Superior Court, the California Court of Appeal, and the California Supreme Court. The court also said the cited regulation did not itself appear to create enforceable benefit rights and that the program was locally funded.
Judge Orrick's order reassigned the case to a district judge and recommended that the case be dismissed with prejudice for lack of jurisdiction. The parties were allowed 14 days after service to object to the recommendation.
The detailed version
- Meder v. City and County of San Francisco, Human Service Agency · No. 3:20-cv-01200
- William Orrick
- Mar. 6, 2020
Background
Elen Meder and Walter Meder filed a civil action concerning the denial of County Adult Assistance Programs (CAAP) aid by the City and County of San Francisco Human Services Agency. The agency determined that the plaintiffs were not permanently residing in the United States. The plaintiffs relied on 20 C.F.R. § 416.1618, which defines when a person is considered to be permanently residing in the United States under color of law.
A CAAP hearing officer affirmed the benefits denial. The plaintiffs then petitioned the San Francisco County Superior Court for a writ of mandate. That court denied the petition on July 10, 2018. The California Court of Appeal affirmed on October 18, 2019, and the California Supreme Court denied review on January 15, 2020.
Screening and Jurisdiction
The court granted the plaintiffs' application to proceed without paying filing fees and screened the complaint under 28 U.S.C. § 1915. The court explained that federal courts must independently ensure that they have subject-matter jurisdiction, meaning legal authority to hear the case.
The court concluded that the Rooker-Feldman doctrine barred the action. That doctrine prevents a federal district court from functioning as an appeals court for state-court judgments. Although the plaintiffs did not expressly describe their federal case as an appeal, the court found that they were effectively seeking to overturn the state-court decisions and obtain the same individual relief denied there: a finding that they were permanently residing in the United States and were entitled to the denied CAAP benefits.
The court also noted that the plaintiffs relied solely on 20 C.F.R. § 416.1618 to establish federal-question jurisdiction. It stated that the regulation appeared only to define residency status and did not itself grant enforceable rights to benefits. The court further observed that CAAP was locally funded rather than a federal program.
Disposition
The court concluded that the complaint was insufficient under the filing-fee screening statute because the court lacked jurisdiction. It reassigned the case to a district judge with a recommendation that the case be dismissed with prejudice for lack of jurisdiction. The parties could file objections with the district judge within 14 days after being served with the report and recommendation. The opinion did not state that the district judge had already adopted the recommendation.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.