On June 14, 2019, we finally received a response to our appeal of Social Services claim that we are operating an unlicensed facility. In a surprise to no one, Social Services denied our appeal. However, we found the timing and contents of the response to be very interesting.

The Timing

The timing of this response is interesting for two reasons. The first is that this letter came a full month after they filed suit against our school on May 15, 2019. And if you remember our Case Update 4, the suit was also filed over a week before our appeal deadline of May 23, 2019. This obviously indicates that Social Services never had any intention of even considering our appeal.

The second reason we find the timing interesting is that it came a week after PJI’s press release about the case. In the press release, PJI specifically called out Social Services for abandoning their own administrative process. Social Services had our Federal case against them dismissed on the basis that their administrative process should be exhausted before the courts get involved. But apparently their own reasoning doesn’t apply to them. It cannot be a coincidence that their response to our appeal came a week after PJI called them out. This is clearly a futile attempt by Social Services to fulfil their administrative responsibilities after the fact.

Their attempt is made even more futile by the fact that the appeal response clearly states that we have additional opportunities for appeal. In other words, Social Services’ administrative process still has not been exhausted. Yet, they continue to attempt this court action against our school.

The Content

This is where things get really interesting. Social Services claims in their denial of our appeal that they are not making “determinations regarding behavioral-based services or private alternative boarding schools.” Instead they are claiming that RVCA is not exempt from licensure because “the school’s function is not education only.”

What that means is that they are not claiming we are in violation of the recently passed SB524. They are claiming that we are in violation of our exemption as a school, which we have operated under for the past 26 years!

Not only that, but Social Services has verified that we are operating legally as a school three times over the past 10 years.

May 22, 2009

In review of your program and submitted documents, it appears that licensure through the California Department of Social Services, Community Care Licensing Division is not required.Mei Yuk Kung, Program Chief, Community Care Licensing Division

March 14, 2013

Based on a review of the information obtained during these interviews it has been determined that the program is not in violation of Title 22 California Code of Regulations pertaining to licensing requirements. The facility is operating as a Christian Boarding school, and as such, exempt from licensure.Julie Darden, Department of Social Services Complaint Investigation Report

June 26, 2015

I am satisfied that for now, based on our conversations today and the agreement that you’ll share the recordings, so that we have that to have a record of what we all talked about. I am satisfied that, at this point, there is no unlicensed care and supervision.Tom Stahl, Regional Manager, Community Care Licensing Division, in person meeting (recorded with permission)

In the time since these confirmations, we have changed very little about the structure of our school. If anything, any changes that we have made were made in an attempt to ensure that we would not violate our status as a school. Especially with the passing of SB524.

Essentially, Social Services is arbitrarily reversing their three previous determinations that we are operating legally as a school. They are reversing these determinations with no new evidence and no new legal justification.

In other words, we have been accused of the same crime three times and been found innocent each time. However, based on no new evidence, Social Services is now basically saying, “Nevermind. You’re guilty!”


Please help support us in our fight against this injustice.

Please contact your church, school, local government officials and express your concern over this abuse of power.