Coast Community College Dist. v. Comm. on State Mandates

Opinion of the Court by Groban, J.

Article XIII B, section 6 of the California Constitution requires the state to reimburse local governments “[w]henever the Legislature or any state agency mandates a new program or higher level of service . . . .” (Cal. Const., art. XIII B, § 6, subd. (a).) In this case, several community college districts seek reimbursement for regulations that specify various conditions the districts must satisfy to avoid the possibility of having their state aid withheld. The conditions describe standards governing several core areas of community college administration, including matriculation requirements, hiring procedures, and curriculum selection. The districts filed a claim with the Commission on State Mandates, “ ‘ “a quasi-judicial body [that] has the sole and exclusive authority to adjudicate whether a state mandate exists” ’ ” (California School Boards Assn. v. State of California (2009) 171 Cal.App.4th 1183, 1200; see Gov. Code, § 17551), arguing that reimbursement was required under Article XIII B, section 6 because: (1) the regulations imposed a legal duty to satisfy the conditions described therein (“legal compulsion”); or (2) the regulations…