Reimbursement of Mandates

Coast Community College District, et al. v. Commission on State Mandates, et al – California Supreme Court (Case No. S262663)

MEMBER(S) INVOLVED: Filed on behalf of all California school districts and county offices of education

IMPORTANCE OF STATEWIDE ISSUE:

School district budgets are affected by determinations of the Commission of State Mandates regarding whether the state has legally or practically compelled the district to implement a new program or higher level of service (thus creating a mandate). The Supreme Court’s decision in this case may modify or reinforce existing law and will likely influence the Commission on State Mandates and lower courts in determining when the state has legally or practically compelled a new reimbursable program or higher level of service to school districts and other local agencies.

SUMMARY OF THE CASE:

Coast Community College District, in conjunction with four other community college districts, challenged the decisions of the Commission on State Mandates regarding claims for reimbursement of mandates associated with 27 Education Code sections and 141 regulations, which include a number of standards and procedures that a community college district must adopt and maintain in order to receive state funding.

The community college districts sought reimbursement for the costs of educational programs and higher-level services newly mandated by state agencies. The Commission denied the community college districts’ claims for reimbursement and the trial court upheld the Commission’s decision, finding that the districts could have chosen to decline state funding instead of complying with the minimum conditions, and as such the regulations were not mandated costs.

In April 2020, the community college districts appealed to the third appellate district. The appellate court overturned the trial court’s decision in part, finding that the requirements for minimum conditions applied to state-mandated programs, and analyzing each applicable regulation to determine whether it was a mandate subject to reimbursement by the state.

The Commission on State Mandates and the state both sought review by the California Supreme Court, which was granted on August 12, 2020.

CURRENT STATUS AND/OR OUTCOME:

On May 17, 2021, the ELA filed an amicus brief in support of the districts, focusing on how unfunded mandates impact local educational agencies (“LEAs”), and arguing that the Commission on State Mandate’s interpretation and application of the Supreme Court’s test set forth in an earlier 2003 case, Department of Finance v. Commission on State Mandates (Kern High School District), risks further whittling away at the long-standing constitutional entitlement of LEAs to receive reimbursement from the state whenever the state mandates a new program or higher level of service. The case is ongoing.