Camacho v. Texas Workforce Commission

To receive Temporary Assistance for Needy Family (TANF) grants, states must ensure that certain recipients participate in “work activities,” defined by 42 U.S.C. § 607 to include unsubsidized employment and job-search and job-readiness assistance, among other enumerated categories. If an individual refused to participate in work activity, the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) required the state to reduce the amount of a family’s assistance or otherwise terminate assistance. A recipient could also lose Medicaid benefits for refusing to work. After the Texas legislature passed legislation implementing the PRWORA requirements, the Texas Workforce Commission (TWC) (defendant) promulgated implementing rules that defined individuals participating in work for purposes of § 607 to include those who engaged in all TANF core and noncore activities. TANF core activities included job-search and job-readiness assistance, which TWC defined to encompass a recipient’s maintenance of their children’s health and dental checkups, immunizations, and school attendance and the recipient’s avoidance of using illicit substances. If a recipient failed to ensure these things for the recipient’s children, the recipient’s medical assistance could be terminated. Soila Camacho (plaintiff) filed suit, arguing that failing to ensure child immunization, checkups, and school attendance and avoid substance abuse could not reasonably be interpreted as components of job-search and job-readiness assistance activities. TWC contended that recipients with children in good health and attending school and recipients who refrain from substance abuse are more likely to get and maintain jobs. The district court found in Camacho’s favor. TWC appealed.