City of Redondo Beach v. Independent Cities etc. CA2/4

INTRODUCTION

The City of Redondo Beach (the City) initiated a lawsuit against the Independent Cities Risk Management Authority (ICRMA), a joint powers authority of which the City was a member. The City sought to overturn an assessment levied on ICRMA’s members on the grounds that it was done in contravention of ICRMA’s governing documents. After a bench trial, relying on stipulated facts and stipulated evidence, the court found in favor of the City and entered judgment against ICRMA. The court subsequently granted the City’s motion for attorney fees and costs. On appeal, ICRMA contends the assessment was done as required by its governing documents. Alternatively, ICRMA argues the City waived and was estopped from challenging the assessment by voting for it. ICRMA further argues the court erred in granting the City’s motion for attorney fees and costs, specifically the award of expert fees and costs. Based on the trial court’s limited findings and failure to rule on evidentiary objections, we reverse the judgment and remand the matter for further proceedings. In light of our holding, we reverse the court’s order granting attorney fees and costs to the City.

FACTUAL AND PROCEDURAL…