People Ex Rel. Younger v. County of El Dorado
96 Cal. Rptr. 553, 487 P.2d 1193, 5 Cal. 3d 480 (1971)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A state legislature may delegate governmental powers, including police powers and funding mandates, to a specially created regional agency if the agency's purpose is to address problems that transcend local political boundaries and are of regional, rather than purely local, concern.
Facts:
- California and Nevada, with congressional approval, entered into the Tahoe Regional Planning Compact to address severe environmental threats to the Lake Tahoe Basin caused by rapid population growth and development.
- The Compact created the Tahoe Regional Planning Agency (Agency), a bi-state entity with jurisdiction over the entire region, including parts of El Dorado and Placer Counties in California.
- The Agency was granted broad powers to create and enforce a comprehensive regional plan for land-use, zoning, conservation, and public services, and to adopt ordinances to effectuate this plan.
- The Compact established a 10-member governing body composed of appointed representatives from counties and cities within the region, state officials, and appointees by the governors of California and Nevada.
- The Compact requires the Agency to establish an annual budget and apportion a share of its cost among the counties in the region, based on the full cash valuation of taxable property.
- The Compact explicitly states that each California county 'shall pay the sum allotted to it by the agency from any funds available therefor'.
- For several fiscal years, the Agency adopted budgets and formally apportioned the required financial contributions to El Dorado County and Placer County.
- El Dorado County and Placer County refused to pay the amounts apportioned to them, challenging the constitutionality of the Compact and the Agency.
Procedural Posture:
- The Attorney General of California, on behalf of the People of the State of California, filed a petition for a writ of mandate directly in the Supreme Court of California.
- The petition sought an order compelling the Counties of El Dorado and Placer to pay the funds apportioned to them by the Tahoe Regional Planning Agency.
- The Supreme Court of California issued an alternative writ of mandate.
- The respondent counties filed an answer, making a return to the alternative writ and arguing the unconstitutionality of the Compact.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Tahoe Regional Planning Compact, which grants a regional agency the power to regulate land use, impose financial obligations on counties, and approve public works, violate California constitutional provisions that grant local police powers to counties and prohibit the Legislature from delegating control over municipal affairs and taxation for local purposes?
Opinions:
Majority - Sullivan, J.
No, the Tahoe Regional Planning Compact does not violate the California Constitution because the problems it addresses are regional, not purely local, in nature. The court reasoned that constitutional limitations on legislative interference with local affairs apply only to purely local matters. The preservation of Lake Tahoe is a regional issue that transcends the boundaries of any single county, making it a proper subject for a state-legislated, multi-jurisdictional solution. The court rejected the counties' specific challenges: 1) The delegation of police power (Art. XI, § 11) is permissible because the powers are for regional purposes, and unlike in prior cases, the Legislature itself, not the Agency, designated violations of ordinances as misdemeanors. 2) The funding mandate (Art. XI, § 12) is not a tax for 'county purposes' but for a broader regional purpose. 3) The delegation to a 'special commission' (Art. XI, § 13) is valid because the Agency serves a more-than-local purpose. Finally, the court found no equal protection violation, holding that the 'one person, one vote' rule does not apply to appointed, non-elected bodies like the Agency's governing board, following the precedent of Sailors v. Board of Education.
Analysis:
This decision is a landmark in environmental and administrative law, affirming the state's power to create regional governing bodies to address problems that individual local governments are unable or unwilling to solve. It establishes the 'regional purpose' doctrine as a critical exception to California's strong constitutional protections for municipal home rule. By distinguishing between 'local' and 'regional' concerns, the case provides a constitutional framework for delegating traditional local powers like zoning and planning to higher-level agencies when faced with large-scale issues like environmental degradation. This precedent paved the way for the creation of other powerful regional agencies in California and serves as a model for interstate environmental cooperation.
