Graham

Appellant Kirkwood Meadows Public Utilities District (the District) appeals from the trial court’s issuance of a writ of administrative mandamus commanding the District to reinstate William K. Graham as an employee of the District. The District contends the trial court erred in concluding the District’s employee residency requirement was unlawful. We shall reverse.

Factual and Procedural Background

The District provides water, sewer, and other public services to the community of Kirkwood, California. The District must respond quickly in the event of water leaks, leaks in wastewater collection, raw sewage spills, power failures, and illegal discharges in wastewater collection. The District also assists with firefighting by ensuring that water storage and pressure is maintained and recharged.

In September 1987, the District’s board of directors enacted Policy Statement No. 445 (Policy 445), which provides that certain employment positions, including water/wastewater operators, “are required to reside within three (3) driving miles of the wastewater treatment plant complex.” Policy 445 expresses the reason for the policy as follows: “The District is located in a remote…