California Attorney General Opinion 25-301

CourtCalifornia Attorney General Reports
DecidedDecember 4, 2025
Docket25-301
StatusPublished

This text of California Attorney General Opinion 25-301 (California Attorney General Opinion 25-301) is published on Counsel Stack Legal Research, covering California Attorney General Reports primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
California Attorney General Opinion 25-301, (Cal. 2025).

Opinion

TO BE PUBLISHED IN THE OFFICIAL REPORTS

OFFICE OF THE ATTORNEY GENERAL State of California

ROB BONTA Attorney General

_______________

: OPINION : : No. 25-301 of : : December 4, 2025 ROB BONTA : Attorney General : : MANUEL M. MEDEIROS : Deputy Attorney General :

Proposed Relator HIRAM SOTO (Relator) has applied for leave to sue the CITY OF POWAY in quo warranto to remove CHRISTOPHER PIKUS from office as a member of the Poway City Council. The application alleges that Pikus’s appointment to the City Council was invalid because it was not supported by the necessary votes of a majority of the eligible councilmembers. Former Councilmember Brian Pepin voted in the majority, and Relator alleges that Pepin was not a resident of his electoral district at the time of the vote and was therefore no longer a qualified councilmember.

While quo warranto may have been available to directly challenge former Councilmember’s Pepin’s right to hold office after he allegedly vacated his district residence and before he cast his vote, Soto may not use the quo warranto remedy to oust current Councilmember Pikus from office by retroactively challenging Pepin’s right to vote. In light of the de facto officer doctrine, which precludes such challenges, we conclude that Relator presents no substantial question of law or fact that warrants judicial resolution and that the public interest would not be served by granting Relator’s application here. Accordingly, the application for leave to sue is DENIED.

BACKGROUND

The critical facts here occurred within a two-month period between November 2024 and January 2025. On November 25, 2024, Councilmember Brian Pepin sent an

1 25-301 email to the Poway City Manager advising that he would be resigning his District 1 seat on the City Council “effective upon my seat being filled with a replacement.” 1 Although a city councilmember’s resignation is generally made effective upon proper delivery of a letter of resignation, the letter may specify an effective date other than the date of delivery. 2 Moreover, in cities that are divided into council districts, state law allows the resigning member to vote on the appointment of a successor. 3 Following submission of his resignation, Pepin absented himself from the next two City Council meetings but attended a later meeting, at which he voted for his successor. 4

When the City Council met on December 3, 2024, without Pepin in attendance, the Council voted to fill Pepin’s seat by appointment, rather than by calling a special election. 5 Two days before the January 21 meeting at which the appointment vote took place, Hiram Soto, our proposed relator, informed the City Attorney that Pepin had vacated his residence in District 1 of Poway “shortly after he submitted his resignation letter.” 6 According to Soto: “Mr. Pepin’s residency in District 1 has been terminated, and he has not established a new residence within the district. This renders him ineligible to continue as a council member, and an immediate vacancy must be declared pursuant to Poway Municipal Code Section 2.04.070(C).” 7 That ordinance provides, in pertinent part: “Termination of residency in a district by a member of the City Council shall create an immediate vacancy for that Council district unless a substitute residence within the district is established within 30 days after the termination of residency.” 8

1 Relator’s Verified Statement of Facts, ¶ 2; id. at Exh. A; City’s Verified Statement of Facts, ¶ 13. 2 Gov. Code, § 1770, subd. (c)(2). 3 Gov. Code, § 36512, subd. (e)(1). 4 See City of Poway, City Council Regular Meeting Minutes (Dec. 3, 2024), https://tinyurl.com/32vpj8sa (Dec. 3 mins.); City of Poway, City Council Regular Meeting Minutes (Dec. 17, 2024), https://tinyurl.com/udys99ea (Dec. 17 mins.); City of Poway, City Council Regular Meeting Minutes (Jan. 21, 2025), p. 6, https://tinyurl.com/59y2tb25 (Jan. 21 mins.). 5 Dec. 3 mins., supra, at p. 4. Within 60 days from the commencement of a vacancy, a city council must either fill the vacancy by appointment or call a special election. (Gov. Code, § 36512, subd. (b).) 6 Declaration of Alan B. Fenstermacher in Support of City of Poway’s Memorandum, Exh. 1, p. 11 (note from Soto to City Attorney Alan Fenstermacher) (Fenstermacher Decl.). 7 Id. at Exh. 1, p. 12. 8 Poway Mun. Code, § 2.04.070(C).

2 25-301 On January 21, the day of the scheduled meeting, the Poway City Attorney provided a legal memorandum to the City Council advising of his disagreement with Soto. He concluded that Pepin was still eligible to hold office “because he has not yet established a new ‘domicile,’ or legal residence” elsewhere. 9 The City Attorney reasoned that “residence” within the meaning of the Municipal Code is a term of art defined by the Elections Code as a person’s domicile or legal residence. 10 He further reasoned that statutes and judicial precedent require that a person cannot lose their domicile until they have gained another. 11

On the same date on which it received the memorandum, January 21, 2025, the City Council voted 3-2 to appoint Christopher Pikus to fill Pepin’s anticipated vacancy. 12 Without apparent objection from the other members, Pepin voted on the appointment, completing the vote majority needed to appoint Pikus as his replacement. Immediately following the vote, Councilmember Pepin “exited the dais,” and Pikus was sworn in and took his seat. 13

On or about February 17, 2025, Soto applied to the Attorney General for leave to sue in quo warranto for the purpose of removing Councilmember Pikus from the District 1 seat. 14 Soto alleges that, prior to voting on his replacement, Pepin relinquished possession of his residence in Poway City Council District 1. 15 He alleges further that, “[b]ecause Mr. Pepin was not a bona fide member of the Poway City Council when he voted to appoint Pikus as the replacement representative for District 1, the appointment is invalid and Pikus does not lawfully hold any position on the Poway City Council.” 16

9 Fenstermacher Decl., Exh. 1, p. 5. Id. at Exh. 1, pp. 5-6; Elec. Code, § 349, subd. (a) (“ʻResidence’ for voting purposes 10

means a person’s domicile”). 11 Fenstermacher Decl., Exh. 1, pp. 6-8; see Gov. Code, § 244, subd. (c); Walters v. Weed (1988) 45 Cal.3d 1, 7. We express no view on the accuracy of the City Attorney’s analysis in the circumstances here. 12 Jan. 21 mins., supra, at p. 6. 13 Ibid. 14 See Cal. Code Regs., tit. 11, §§ 1, 2. 15 Proposed Complaint, ¶ 8.E; Relator’s Verified Statement of Facts, ¶ 6.B. 16 Proposed Complaint, ¶ 8.F, capitalization altered. Relator also alleged that Pepin had executed a deed of trust to purchase a residence in Morgan Hill, California. (Id. at ¶ 8.D.) Relator has apparently abandoned the suggestion that the Morgan Hill home is Pepin’s domicile after undisputed evidence showed that the deed of trust was, in fact, for the purpose of obtaining a home equity loan on property that Pepin had already owned for (continued…)

3 25-301 The City of Poway opposes Soto’s application. Councilmember Pikus himself, though named as the “real party in interest,” submitted no opposition.

The City does not deny that Pepin had vacated his residence in District 1, but—as the City Attorney previously opined—the City argues that Pepin’s former residence constituted his “domicile,” or legal residence, and that under applicable case law, his former home remains his “domicile” until he gains a new one. 17

In support of the City’s opposition, former Councilmember Pepin filed his own declaration, stating: “In November 2024, I vacated my residence at 13924 Olive Mesa Court in the City of Poway (‘Poway Residence’), but as of January 21, 2025, I had not established a new permanent residence.

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California Attorney General Opinion 25-301, Counsel Stack Legal Research, https://law.counselstack.com/opinion/california-attorney-general-opinion-25-301-calag-2025.