The Department administers these programs. (§ 10600; Fry v. Saenz (2002) 98 Cal.App.4th 256, 259-260 [ 120 Cal.Rptr.2d 30] CalWORKs ( Fry); Aktar v. Anderson (1997) 58 Cal.App.4th 1166, 1174 [ 68 Cal.Rptr.2d 595] [FSA] ( Aktar).) A. FOOD STAMPS.

Under both Title II of the ADA and the Rehabilitation Act, a person with a disability is "qualified" to receive government benefits or services or to participate in a government program or activity if the person "is one who, 'with or without reasonable modifications to rules, policies, or practices, . . . meets the essential eligibility requirements' for such benefits, services, or participation." (Fry v. Saenz (2002) 98 Cal.App.4th 256, 263 (Fry); see 42 U.S.C. § 12131(2) [Title II definition of "[q]ualified individual with a disability"].) Borrowing language from Title I of the ADA, which concerns employment discrimination and defines a qualified individual "in terms of employment" (Mary Jo C. v. New York State & Local Retirement System (2d Cir. 2013) 707 F.3d 144, 169 (Mary Jo C.),

Because the purpose to be accomplished by the section 11403 benefit cannot be achieved without the graduation by 19 requirement, we conclude the requirement is an essential component of that benefit. (See Fry v. Saenz (2002) 98 Cal.App.4th 256, 276 (Fry) [conc. opn. of Hull, J] [inclination to defer to Legislature’s implied determination graduation by 19 requirement is essential eligibility requirement as purpose of benefit program could not be achieved without the requirement].) In analyzing the related matter of whether a reasonable modification could be made to the section 11403 benefit, we look at whether a modification would “alter[ ] the essential nature of the program or imposes an undue burden or hardship in light of the overall program.”

) Department is charged with administering CalWORKs. (§ 11209; see also Fry v. Saenz (2002) 98 Cal.App.4th 256, 260 [ 120 Cal.Rptr.2d 30].) Like the former AFDC program, CalWORKs provides cash grants to families with minor children who meet certain requirements, including limited income and resources, and are deprived of the support of one or both parents due to factors such as absence, disability or unemployment.

"`CalWORKs provides aid and services to families with related children under 18 whose parent or parents cannot support them due to death, incapacity, incarceration, unemployment, or continued absence from the home.'" ( Sheyko v. Saenz (2003) 112 Cal.App.4th 675, 682 [ 5 Cal.Rptr.3d 350], quoting Fry v. Saenz (2002) 98 Cal.App.4th 256, 260 [ 120 Cal.Rptr.2d 30]; see Barron v. Superior Court (2009) 173 Cal.App.4th 293, 299 [ 92 Cal.Rptr.3d 394]; § 11250.) The program provides cash aid based on factors including family size and regional housing costs, up to a "maximum aid payment."

If plaintiffs had alleged, for example, that the DHCS operates Medi-Cal so as to exclude Latinos from the program, or to prevent them from receiving benefits provided to other beneficiaries under the program, they would state a claim under section 11135. (See e.g., Hector F. v. El Centro Elementary School Dist. (2014) 227 Cal.App.4th 331, 333, 335, 342 [father of student afflicted with numerous emotional disabilities who was bullied at school and thus deprived of all the benefits of a public education, had standing to sue district on behalf of student under antidiscrimination and harassment laws, including § 11135]; Fry v. Saenz (2002) 98 Cal.App.4th 256, 260-261 [applying department's "completion rule" unlawfully denied children "the benefits of the CalWORKs program on account of their disabilities"].) However, section 11135 and Regulation 11154 are not, on their face, amenable to a claim that, while the Medi-Cal program is accessible to, and all services provided by the program are available to, any individual who qualifies, including Latinos, the program does not provide Medi-Cal beneficiaries with the extent of coverage or the range of provider choices that may be available to other California residents who participate in other health insurance plans.

(Code Civ. Proc., § 1094.5, subd. (b).) On appeal, jurisdictional and procedural fairness challenges present questions of law, which we review de novo. (See, e.g., Doe v. Regents of University of California (2016) 5 Cal.App.5th 1055, 1073 (UCSD); Fry v. Saenz (2002) 98 Cal.App.4th 256, 262 (Fry).) Unspecified statutory references are to the Code of Civil Procedure.

Regardless of the standard we apply to the County's factual findings, we review questions of statutory interpretation and other questions of law de novo. ( Fry v. Saenz (2002) 98 Cal.App.4th 256, 262, 120 Cal.Rptr.2d 30.) C. The finding that Mill Site Road is unnecessary for public use

Here, plaintiffs contend the Lands Commission failed to consider other public trust uses and to impose conditions mitigating impacts on those uses to the greatest extent possible—in other words, plaintiffs claim the Lands Commission failed to comply with asserted procedural requirements of the public trust doctrine. This is a legal issue subject to de novo review under both Code of Civil Procedure sections 1085 and 1094.5. (See Vineyard, supra, 40 Cal.4th at pp. 427 & fn. 4, 435, 53 Cal.Rptr.3d 821, 150 P.3d 709 [concluding “we determine de novo whether the agency has employed the correct procedures” in a case where appellant sought writ under both sections]; Palmer/Sixth Street Properties, L.P. v. City of Los Angeles (2009) 175 Cal.App.4th 1396, 1405, 96 Cal.Rptr.3d 875 [“in either case the standard of review would be the same because there are no disputed issues of fact”]; Fry v. Saenz (2002) 98 Cal.App.4th 256, 262, 120 Cal.Rptr.2d 30 [“whether under Code of Civil Procedure section 1085 or section 1094.5, we review questions of law de novo”].) 3.

Here, plaintiffs contend the Lands Commission failed to consider other public trust uses and to impose conditions mitigating impacts on those uses to the greatest extent possible—in other words, plaintiffs claim the Lands Commission failed to comply with asserted procedural requirements of the public trust doctrine. This is a legal issue subject to de novo review under both Code of Civil Procedure sections 1085 and 1094.5. (See Vineyard, supra, 40 Cal.4th at pp. 427 & fn. 4, 435 [concluding "we determine de novo whether the agency has employed the correct procedures" in a case where appellant sought writ under both sections]; Palmer/Sixth Street Properties, L.P. v. City of Los Angeles (2009) 175 Cal.App.4th 1396, 1405 ["in either case the standard of review would be the same because there are no disputed issues of fact"]; Fry v. Saenz (2002) 98 Cal.App.4th 256, 262 ["whether under Code of Civil Procedure section 1085 or section 1094.5, we review questions of law de novo"].) 3.