County of Los Angeles v. Commission on State Mandates

A 1995 amendment to Penal Code section 13519 requires local law enforcement officers to participate in two hours of domestic violence training. The issue on appeal is whether this amendment resulted in a reimbursable state-mandated program within the meaning of article XIII B, section 6 of the California Constitution for the time spent by local law enforcement officers in such domestic violence training, although such officers were already required to spend 24 hours in continuing education training and the domestic violence training could be included within this total.

This administrative mandamus proceeding was commenced by the County of Los Angeles (County) on a “test claim” filed with and denied by the Commission on State Mandates (Commission) for the County’s costs incurred pursuant to section 13519. The trial court found that California Constitution article XIII B, section 6 required the state to reimburse the County for domestic violence training because the County’s needs and priorities might be detrimentally affected when the state took away two hours of training by mandating that two specific hours of training occur. The trial court remanded the proceedings to…