Tanimura & Antle Fresh Foods, Inc. v. Salinas Union High Sch. Dist.

*779 In this appeal we consider whether a school district acted reasonably in imposing school impact fees on a new residential development project intended to house adult seasonal farmworkers employed by the company. The trial court found that there was no reasonable relationship between the fee and the project's impact on school enrollment and so granted the developer's petition for writ of mandate to refund the fees. The school district contends this was error because the authorizing statute does not require that school districts anticipate and analyze specific use cases for subtypes of residential housing, e.g., adult employees only. Rather, the law requires a reasonable relationship between the fee's use, the need for the school facilities, and the type of development project-in this case, residential. The district also contends that the potentially discriminatory exclusion of children from a new residential development should not form an escape hatch for the developer to avoid paying mitigation fees under the statute.

We find, as explained herein, that the statutes governing the imposition of school impact fees do not require a school district to separately analyze the…