Reimbursement of Mandates

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

MEMBERS INVOLVED: All California school districts and county offices of education

IMPORTANCE OF STATEWIDE ISSUE:

School district budgets are affected by determinations of the Commission on State Mandates (Commission) 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 courts’ decisions in this case may modify or reinforce existing law and will likely influence the Commission and lower courts in determining when the state has legally or practically compelled a school district or other local agency to implement a new reimbursable program or higher level of service.

SUMMARY OF THE CASE:

In this case now before the Court of Appeal for further consideration, multiple community college districts have successfully challenged decisions of the Commission 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 Commission denied the community college districts’ claims for reimbursement, and the trial court upheld the Commission’s decision, finding that the districts could decline state funding instead of complying with the minimum conditions, and, as such, the regulations were not mandated costs. 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 specific claim for reimbursement. The Commission and State both sought review by the California Supreme Court.

On May 17, 2021, the ELA filed an amicus brief in support of the districts, focusing on how unfunded mandates impact LEAs, and arguing that the Commission’s interpretation and application of the Supreme Court’s test set forth in a 2003 case, Department of Finance v. Commission on State Mandates (Kern High School District), risks further whittling away at the longstanding constitutional entitlement of school districts and COEs receiving reimbursement from the state whenever the state mandates a new program or higher level of service.

CURRENT STATUS AND/OR OUTCOME:

On Aug. 15, 2022, the California Supreme Court issued a decision that reversed the court of appeal’s judgment and remanded the matter back to the court of appeal for further consideration. The Supreme Court’s opinion focused on the distinction between legal compulsion and practical compulsion in the law, describing that reimbursement is appropriate when either occurs. The Court reversed the appellate court’s decision and found that, based on the fact that the withholding of funding is only a possibility and not a certainty, the statute and regulations at issue do not contain any mandatory legal obligation and therefore, there is no legal compulsion requiring reimbursement. As for considerations of practical compulsion, the Court found it appropriate for the court of appeal to consider the issue seeing as it did not do so after finding a legal compulsion.

Back to Report