Coachella Valley Mosquito and Vector Control v. City of Indio

1. Introduction

Do cross-complaints filed in response to a reverse validation action survive after the primary action has been dismissed because of lack of jurisdiction for failure to serve it properly? We hold that that jurisdiction over the cross-complaints was never completed and they should also be dismissed.

2. Factual and Procedural Background

On November 29, 1999, the City of Indio enlarged the Indio Merged Redevelopment Project Area by adopting Ordinance No. 1260. On January 26, 2000, plaintiff Coachella Valley Water District (Water District) filed a reverse validation action challenging Ordinance No. 1260. In particular, the Water District charged that the proposed amendment area was not physically or economically blighted or predominantly urbanized as required by the Community Redevelopment Law. The named defendants included appellants Coachella Valley Mosquito and Vector Control District (Mosquito District) and Valley Sanitary. The Water District served and published a summons calling for interested parties to file a response by March 17, 2000. On that date, the Mosquito District and Valley Sanitary filed answers and also filed cross-complaints against three…