Latest Case: California School Boards Ass'n v. State (Constitutional Law)

Taking Stock: A Review of Justice Stevens’s Last Book and an Appreciation of His Extraordinary Service on the Supreme Court

RODGER CITRON

Rodger D. Citron, the Associate Dean for Research and Scholarship and a Professor of Law at Touro College, Jacob D. Fuchsberg Law Center, comments on the late Justice John Paul Stevens’s last book, The Making of a Justice: Reflections on My First 94 Years. Citron laments that, in his view, the memoir is too long yet does not say enough, but he lauds the justice for his outstanding service on the Supreme Court.

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California School Boards Ass'n v. State

Docket: S247266

Opinion Date: December 19, 2019

Judge: Goodwin Liu

Areas of Law: Constitutional Law, Education Law

In deciding whether the Legislature's enactment of two statutes requiring a portion of state funding provided annually to local education agencies to be used prospectively as "offsetting revenues" under Cal. Gov't Code 17557(d)(2)(B) was constitutional the Supreme Court held that the method chosen by the Legislature to pay for two existing state reimbursement mandates did not on its face violate the state Constitution. In 2010, during a period of economic recession, the Legislature enacted the two statutes at issue in this case to satisfy the two mandates. The statutes designated previously non-mandate education funding as restricted funding at the beginning of the next fiscal year to satisfy the state's obligation to reimburse school districts for the two mandates. Petitioner filed a petition for writ of mandate and complaint for injunctive and declaratory relief alleging that the two statutes violate the Constitution. The superior court denied the petition, and the court of appeal affirmed. The Supreme Court affirmed, holding that mandate reimbursement as provided by the statutes does not violate the Constitution.