County of Alameda v. Carleson

In County of Alameda v. Carleson (1971) 5 Cal. 3d 730, several counties sued a state agency for a declaration that certain regulations pertaining to eligibility for welfare benefits were invalid. The relief sought would have terminated grants to some welfare recipients. Three individual recipients and the California Welfare Rights Organization (collectively CWRO) sought to intervene, but the motion was denied. After judgment was entered declaring the regulations invalid, CWRO moved to vacate the judgment, again unsuccessfully. It appealed both the denial of the motion to intervene and the judgment. (Id. at pp. 734-735.) The court explained that "one who is legally 'aggrieved' by a judgment may become a party of record and obtain a right to appeal by moving to vacate the judgment pursuant to Code of Civil Procedure section 663." (County of Alameda v. Carleson, supra, 5 Cal. 3d at p. 736.) One is aggrieved when the judgment has an immediate, pecuniary, and substantial effect on his interests or rights. (Id. at p. 737.) The court held that CWRO's motion to vacate made it a party entitled to appeal, and it was legally aggrieved because the judgment, in terminating its members' benefits, had an immediate, pecuniary, and substantial effect upon their rights. (Id. at pp. 736-737.)