San Francisco Unified School District v. City & County of San Francisco

*1073 Opinion

The San Francisco Unified School District (School District) filed an action for declaratory relief and a petition for a writ of mandate against the City and County of San Francisco (City) seeking a determination that the joint civil service system of employment for City and School District employees established by Education Code section 45318, as applied by the City, transfers school control to an entity outside the public school system, in violation of article DC, section 6 of the California Constitution. The trial court rejected the claim and entered judgment in favor of the City and employee unions that intervened on the City’s side. We affirm the judgment.

I. FACTUAL AND LEGAL BACKGROUND

California has a statewide public education system managed locally by school districts that are distinct from municipalities. (Cal. Const., art. IX, §§ 5, 14.) The School District and City share coterminous geographic boundaries but are separate and autonomous government entities. The School District and City are each governed by a separate elected body, managed by a separate chief executive, funded by different sources of revenue, subject to different budgets, and…