Broadmoor Police Protection District v. San Mateo Local Agency Formation Commission

— This case concerns the constitutionality of the protest provisions regarding municipal and county service area reorganizations and annexations contained in the Cortese-Knox Local Government Reorganization Act of 1985 (the Act), Government Code section 56000 et seq. Broadmoor Police Protection District (Broadmoor) appeals from a judgment on the pleadings entered in favor of respondents, the City of Daly City (City) and San Mateo County Local Agency Formation Commission (LAFCO). Broadmoor contends that the mechanism for determining a majority protest under the statute violates the equal protection clauses of the state and federal Constitutions. We have concluded that the statute passes constitutional muster, and therefore affirm.

Factual and Procedural Background

City filed a proposal for reorganization with LAFCO on September 25, 1990, seeking annexation of 30.75 acres in an area just north of Colma. This reorganization entailed the detachment of the subject area from appellant Broadmoor and from the Colma Fire Protection District. After a public hearing in accordance with the Act, LAFCO approved the reorganization on February 20, 1991. LAFCO found that the territory…