San Francisco Labor Council v. Regents of University of California
608 P.2d 277, 163 Cal. Rptr. 460, 26 Cal. 3d 785 (1980)
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Rule of Law:
A state statute that dictates minimum salary levels for university employees by requiring payment of prevailing wages is an unconstitutional infringement on the university's autonomy. Such salary determination is an internal affair of the university, not a matter of statewide concern that would permit legislative regulation under the California Constitution.
Facts:
- The Regents of the University of California employed laborers, workmen, and mechanics on an hourly or per diem basis.
- The California Legislature enacted Education Code section 92611.
- This statute required the Regents to ascertain the general prevailing wage rates for such positions in various localities throughout the state.
- The statute mandated that the Regents not fix the minimum salary limits for these employees below the ascertained general prevailing rate for each locality.
Procedural Posture:
- Plaintiffs filed a petition for a writ of mandate in the superior court to compel the Regents of the University of California to comply with Education Code section 92611.
- The Regents (defendants) filed a demurrer, arguing the statute was unconstitutional.
- The superior court (trial court) sustained the Regents' demurrer without leave to amend.
- The trial court entered a judgment of dismissal in favor of the Regents.
- Plaintiffs (appellants) appealed the judgment of dismissal.
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Issue:
Does California Education Code section 92611, which requires the Regents of the University of California to set minimum salaries for certain employees at or above the local prevailing wage rate, unconstitutionally interfere with the autonomy and powers of organization and government granted to the Regents under Article IX, section 9 of the California Constitution?
Opinions:
Majority - Clark, J.
Yes. Education Code section 92611 unconstitutionally interferes with the autonomy granted to the Regents. Article IX, section 9 of the California Constitution grants the Regents 'full powers of organization and government,' making the university operate as independently of the state as possible. Legislative regulation is permissible only in three limited areas: 1) appropriations, 2) general police power regulations applicable to all private entities, and 3) matters of statewide concern not involving internal university affairs. The prevailing wage statute does not qualify as an appropriation or a general police power regulation, as it is not applicable to all private employers. Furthermore, citing Sonoma County Organization of Public Employees v. County of Sonoma, the court concluded that setting employee compensation is not a matter of statewide concern but is a core internal affair, analogous to how salary setting is a local concern for charter cities. Therefore, the statute impermissibly intrudes upon the Regents' exclusive constitutional authority.
Analysis:
This decision strongly reaffirms the unique constitutional autonomy of the University of California, distinguishing it from other state agencies that are subject to comprehensive legislative control. It establishes that employee salary determination is a core 'internal university affair,' shielding it from direct legislative interference unless the regulation is a matter of true statewide concern or a general law applicable to the public at large. The ruling limits the Legislature's ability to impose specific employment conditions on the university, forcing it to rely on its power of appropriation or on passing more generally applicable laws to influence university policy.
