Ste. Marie v. Riverside County Regional Park & Open-Space District

We address today a question of statutory interpretation, the answer to which will have a profound effect on how regional park and open space districts can manage their real property holdings. The dispute in this case centers on a purported conflict between Public Resources Code section 5565, which suggests real property is deemed “dedicated” for park or open space purposes at the moment of acquisition by a district, and section 5540, which suggests land is “actually dedicated” only after a district’s board of directors adopts a formal resolution for such purposes. The difference is important because a district’s ability to sell or otherwise convey land “actually dedicated” under section 5540 is limited by substantial statutory restrictions. The Court of Appeal below held that certain real property owned by defendant Riverside County Regional Park and Open-Space District (hereafter the Riverside District or the District) was—immediately upon acquisition—deemed by section 5565 “actually dedicated” for park or open space purposes within the meaning of section' 5540, despite the absence of any affirmative action by the District’s board of directors so designating the…