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Board of Supervisors of Sacramento County v. Local Agency Formation Commission

3 Cal. 4th 903, 13 Cal. Rptr. 2d 245, 838 P.2d 1198 (1992)

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Board of Supervisors of Sacramento County v. Local Agency Formation Commission

California Supreme Court

3 Cal. 4th 903, 13 Cal. Rptr. 2d 245, 838 P.2d 1198 (1992)

Facts

In 1986, residents of an unincorporated area called Citrus Heights in Sacramento County (county) collected enough valid signatures to qualify to petition the Sacramento County Local Agency Formation Commission (commission) (defendant) for incorporation. The commission approved a resolution that relocated a sales-tax rich shopping center from the proposed city limits to mitigate the financial impact on the county. Requests were submitted for reconsideration of the resolution, and the commission adopted another resolution that removed another shopping center from the proposed city limits and required the city to phase in taxes more slowly. The commission ordered a confirming election. Under Government Code § 57103, only the voters residing in the territory to be incorporated could vote in the confirming election. The county Board of Supervisors, county Deputy Sheriffs’ Association, and Sacramentans to Save our Services (plaintiffs) sued the commission, alleging that § 57103 violated the Equal Protection Clause of the Fourteenth Amendment. The appeals court found § 57103 unconstitutional. The commission appealed.

Rule of Law

Issue

Holding and Reasoning (Mosk, J.)

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