Ramos v. County of Madera

In Ramos v. County of Madera (1971) 4 Cal. 3d 685, the California Supreme Court was presented with the issue of what functions performed by county employees were "discretionary" in order to determine if the public entity immunity for discretionary decisions applied to their determinations related to the plaintiffs' eligibility under the prior GAIN program. ( Id. at p. 692.) The high court held that the county defendant was not immune from liability because it and its employees did not exercise "discretion" when making determinations regarding eligibility for welfare benefits. ( Id. at p. 694.) Because the Legislature had provided standards of eligibility under GAIN, county employees' exercise of judgment in determining if a recipient met those requirements did not constitute an exercise of discretion. (Ibid.) The court determined that it is only actual policy level determinations that amount to an exercise of discretion. ( Id. at pp. 693-695.) Policy decisions are those such as " 'planning' as opposed to the 'operational' level of decisionmaking." ( Id. at p. 693.) The county's actions in making eligibility determinations under the guidelines provided by the Legislature amounted to only ministerial acts that were not immune from liability. ( Id. at p. 695.)