County of San Bernardino v. West Valley Water Dist.

CourtCalifornia Court of Appeal
DecidedFebruary 1, 2022
DocketE078248
StatusPublished

This text of County of San Bernardino v. West Valley Water Dist. (County of San Bernardino v. West Valley Water Dist.) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
County of San Bernardino v. West Valley Water Dist., (Cal. Ct. App. 2022).

Opinion

Filed 2/1/22

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION TWO

COUNTY OF SAN BERNARDINO,

Plaintiff and Respondent, E078248

v. (Super.Ct.No. CIVSB2113136)

WEST VALLEY WATER DISTRICT, OPINION

Defendant and Appellant.

APPEAL from the Superior Court of San Bernardino County. David S. Cohn,

Judge. Affirmed.

Reed & Davidson, Stuart L. Leviton and Nathan R. Hardy for Defendant and

Appellant.

Tom Bunton, County Counsel, Jolena E. Grider, Deputy County Counsel for

Plaintiff and Respondent.

Defendant and appellant West Valley Water District (District) appeals the entry of

a stipulated judgment in favor of plaintiff and respondent County of San Bernardino

1 (County) ordering that the District conduct its elections on a statewide general election

date starting in November 2022.

The sole issue on appeal is whether the District is authorized pursuant to Elections

Code section 140521 to designate the statewide primary election date starting in June

2022 for its elections or whether the District is required to hold its election on a statewide

general election date starting in November 2022.

We conclude the District must hold its election on the statewide general election

date starting in November 2022. In 2015 the California Legislature enacted the

California Voter Participation Rights Act (§§ 14050-14057) (VPRA). (Stats. 2015,

c. 235 (S.B. 415), § 1, eff. Jan. 1, 2016, operative Jan. 1, 2018; hereinafter SB 415.) The

primary goal of the VPRA was to increase voter turnout. It mandates that if voter turnout

for an election set by a political division that is not on a statewide primary or general

election date results in voter turnout that is at least 25 percent less than the average voter

turnout within that political subdivision for the previous four statewide general elections,

it must change its election date to either the statewide primary or general election date.

However, the VPRA did not eradicate all existing voting laws and does not conflict with

sections 1303 or 10404, which require that the District set its election date on the

statewide general election date.

1 All further statutory references are to the Election Code unless otherwise indicated.

2 FACTUAL AND PROCEDURAL HISTORY

This case involves a statutory interpretation of the Elections Code. A brief

overview of the relevant statutes is helpful in understanding the pleadings filed by the

parties. The three most relevant statutes are sections 10404, subdivision (b); 1303,

subdivision (b); and 14052, subdivision (a).

Section 14052, subdivision (a), provides in pertinent part, “[A] political

subdivision shall not hold an election other than on a statewide election date if holding an

election on a nonconcurrent date has previously resulted in a significant decrease in voter

turnout.”2 “ ‘Significant decrease in voter turnout’ means the voter turnout for a

regularly scheduled election in a political subdivision is at least 25 percent less than the

average voter turnout within that political subdivision for the previous four statewide

general elections.” (§ 14051, subd. (b).) Existing law at the time the VPRA was enacted

included section 10404, subdivision (b), which provides in pertinent part,

“Notwithstanding any other law, a governing body of a special district may, by

resolution, require that its elections of governing body members be held on the same day

as the statewide general election.” Section 1303, subdivision (b), provides,

“Notwithstanding any other provision of law, a governing body of a special district may

require, by resolution, that its elections of governing body members be held on the same

day as the statewide general election.”

2 The VPRA also refers to “on-cycle” and “off-cycle” elections, with the former being an election held at the same time as statewide elections and the latter being elections held on other nonconcurrent dates. (City of Redondo Beach v. Padilla (2020) 46 Cal.App.5th 902, 906, fn. 2 (Redondo Beach).)

3 A. THE COUNTY’S PETITION FOR WRIT OF MANDATE AND

COMPLAINT FOR DECLARATORY RELIEF

On May 14, 2021, the County filed its Petition for Writ of Mandate and Complaint

for Declaratory Relief against the District (Petition). The District had submitted to the

County Board of Supervisors Resolution 2021-1 (Resolution) seeking approval of

changing the District’s election date from the existing date of November in odd-

numbered years to the statewide primary election date in even-numbered years

commencing in June 2022. The County sought emergency relief to order the District to

change its election date to the statewide general election beginning in November 2022

and declaratory relief regarding the validity of the Resolution.

The County alleged that the District had been conducting its elections in

November of odd-numbered years. The Resolution sought to change the date of elections

to even-numbered years on statewide primary elections dates with the first election

occurring in June 2022. On February 2, 2021, the County informed the District that it

must change its election date to the statewide general election date and not the statewide

primary date. On February 19, 2021, the District filed the Resolution with the County’s

Registrar of Voters and the clerk of the County’s Board of Supervisors seeking approval.

The County argued that if the Resolution was approved by the Board of Supervisors, it

would result in an illegal election. The District refused to change the Resolution. The

County alleged that the Registrar of Voters had determined that the average voter turnout

for the District’s elections in November of odd-numbered years was at least 25 percent

less than the turnout for the last four statewide general elections.

4 The County insisted that section 10404, which the District contended was

applicable to the District even after the VPRA, made it clear that the District’s election

must take place on the statewide general election date. The County also referred to

section 1303, subdivision (b). The County insisted that these three statutes—the VPRA,

section 1303, and section 10404—must be considered as a whole. Section 10404 was

applicable to the District because it was a special district and currently held its elections

in odd-numbered years.

The County alleged that the VPRA was enacted to increase voter participation by

requiring elections to be held on a statewide election date. Further, since the District was

required to move its existing election date, sections 10404 and 1303 were not permissive

as to the District. The County provided that the voter participation for the prior District

election in November 2019 was 10.79 percent. The turnout for the four prior statewide

general elections was 61.54 percent. The prior four statewide primary elections had a

voter turnout of 32.97 percent. Based on these statistics, voter turnout for statewide

general elections was significantly higher and the intent of the VPRA was to increase

voter turnout.

The County wanted the trial court to issue an order that the District must amend

the Resolution to provide for the District’s election be held on the statewide general

election date in even-numbered years beginning in November 2022. The County also

sought declaratory relief.

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County of San Bernardino v. West Valley Water Dist., Counsel Stack Legal Research, https://law.counselstack.com/opinion/county-of-san-bernardino-v-west-valley-water-dist-calctapp-2022.