Does the California Department of Health and Social Services have to exclude involuntary payroll deductions from income for the purposes of calculating future income?

In County of Alameda v. Carleson, supra, 5 Cal.3d 730, 97 Cal.Rptr. 385, 488 P.2d 953, app. dism. (1972) 406 U.S. 913, 92 S.Ct. 1762, 32 L.Ed.2d 112 we held that the department's policy of excluding involuntary payroll deductions from income was proper since "only net income available for current use on a regular basis should be considered.... (45 C.F.R. 233.20(a)(3)(ii)(c)." We further approved the department's then applicable policy of treating such monies as resources when refunded, finding the distinction between recurring and nonrecurring lump-sum payments

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