California Supreme Court Watch

Aug 12, 2020
Coast Community College Dist. v. Commission on State Mandates, S262663.

#20-205 Coast Community College Dist. v. Commission on State Mandates, S262663. (C080349; 47 Cal.App.5th 415; Sacramento County Superior Court; 34201480001842CUWMGDS.) Petition for review after the Court of Appeal affirmed in part and reversed in part the judgment in a civil action. This case presents the following issues: (1) Is the cost of complying with regulations that establish minimum conditions for community college districts to receive state aid a reimbursable state mandate within the meaning of article XIII B, section 6, of the state Constitution? (2) Does a trial court lack jurisdiction under article XIII B, section 6, to make subvention findings as to statutes that were not specifically identified in an initial test claim? (3) Does a trial court lack jurisdiction to remand a test claim based on a statute that was the subject of a prior final decision by the Commission on State Mandates? The court directed the Reporter of Decisions not to publish the opinion in this matter in the Official Appellate Reports.

Review granted; issues limited: 8/12/2020

Case fully briefed: 4/16/2021

Cause argued and submitted: 6/8/2022

Opinion filed: Judgment reversed: 8/15/2022

See the California Court of Appeal Opinion.

See the Petition for Review (Commission on State Mandates).

See the Petition for Review (Department of Finance).

See the California Supreme Court Opinion.  (Coast Community College Dist. v. Commission on State Mandates (2022) 13 Cal.5th 800.)

“We reverse. Contrary to the Court of Appeal’s interpretation [of regulations specifying various conditions the districts must satisfy to avoid having their state aid withheld], the fact that the standards set forth in the regulations relate to the districts’ core functions (matriculation, hiring of faculty and selecting curriculum, etc.) does not in itself establish that the districts have a mandatory legal obligation to adopt those standards…. The regulations make clear that if a district fails to comply, the California Community Colleges Chancellor has discretion to pursue any number of remedial measures that range from taking no action to ‘withhold[ing] or reduc[ing] all or part of the district’s state aid.’ (Cal. Code Regs., tit. 5, § 51102, subd. (b)(5).) Thus, the districts are not legally obligated to adopt the standards described in the regulations, but rather face the risk of potentially severe financial consequences if they chose not to do so. Because the regulations induce rather than obligate compliance, legal compulsion is inapplicable.”

“Because the Court of Appeal chose not to address whether the districts established practical [rather than legal] compulsion, we will remand the matter to allow the court to evaluate that issue in the first instance.”

“The Court of Appeal’s judgment is reversed and the matter is remanded for further proceedings consistent with this opinion.”

Justice Groban authored the opinion of the Court, in which Chief Justice Cantil-Sakauye and Justices Corrigan, Kruger, Jenkins, and Guerrero concurred.

Justice Liu filed a concurring opinion.