City of Anaheim v. State of California

The City of Anaheim (hereafter City) sought reimbursement for costs it allegedly incurred as a result of the enactment of Assembly Bill No. 2674 (Stats. 1980), chapter 1244, page 4220 (hereafter 1244/80). The State Board of Control (hereafter Board) denied City’s claim. City thereafter filed a petition in the superior court seeking a writ of mandate and declaratory relief. City now appeals from the judgment denying its petition. We affirm.

Procedural History

On October 19, 1981, City filed a “test claim” (former Rev. & Tax. Code, § 2218, subd. (a)) seeking reimbursement of the $153,614.61 it alleged it incurred during the 1981 fiscal year to comply with 1244/80. This test claim was amended on May 6, 1982. As amended, the test claim alleged the following bases for reimbursement: (1) the transfer of funds out of the Public Employees’ Retirement System’s (hereafter PERS) reserve for deficiencies account caused a reduction in the interest credited to City’s account thereby requiring a higher employer contribution rate; (2) 1244/80 removed City’s former option of negotiating with its employees to increase the cost of living allowance; and (3) 1244/80 increased the cost of an…