European Union – Citizenship. The Court of Appeal, Civil Division, held that Zambrano carers (see Zambrano v Office National de l'Emploi (ONEm)[2011] All ER (EC) 491), who were in need and unable to work were not entitled to the same level of assistance as was required by European Union law to be paid to EU citizens lawfully resident in the United Kingdom. The UK had to pay them such amount as would enable them to support themselves in order to be the carer for the EU citizen child within the EU, but subject to that, might determine to pay social assistance to them on some different basis.