Goff v. Commission on State Mandates

BILLY GOFF Et Al., Appellants. v. COMMISSION ON STATE MANDATES, Respondent COUNTY OF SACRAMENTO Et Al., Real Parties In Interest C.A. 3rd, No. C022434 S067026 California Supreme Court Filed March 11, 1998
        Real Parties In Interest's petition for review DENIED.
        Kennard, J., and Brown, J., are of the opinion the petition should be granted.
        The Reporter of Decisions is directed not to publish in the Official Appellate Reports the opinion in the above-entitled appeal filed November 25, 1997, which appears at 59 Cal.App.4th 586. (Cal. Const., art. VI, section 14, rule 976, Cal. Rules of Court.)

(Editor Note - For your convenience we reprint below the Daily Journal's Ruling Column brief which summarized the earlier decision of the lower court.)


GOVERNMENT

County's finding of financial distress allowing reduction of welfare benefits is reviewed under independent judgment test.
        The C.A. 3rd has determined that a county's finding of financial distress, which would allow it to reduce it general assistance benefits pursuant to procedure outlined in Welfare and Institutions Code Section 17000.6, must be reviewed under the independent judgment test, not a substantial evidence standard.
        When Sacramento County faced a large projected budget shortfall it sought to reduce its general assistance benefits pursuant to Section 17000.6. The Commission on State Mandates found that the county had made a showing of significant financial distress that would permit it to lower general assistance aid to a lower level. Billy Goff and other general assistance recipients, filed a petition for a writ of mandate and a complaint for declaratory and injunctive relief challenging the Commission's determinations. The trial court upheld the Commission's findings. Goff contended that the trial court erred in applying the substantial evidence standard of review to the Commission's finding of significant financial distress, and argued that the trial court should have exercised its independent judgment in reviewing the Commission's decision.
        The C.A. 3rd reversed and remanded. Section 17000.6 provides that a county can adopt a level of general assistance below statutory levels if a finding is made that maintaining the statutory level would result in significant financial distress to the county. "Significant financial distress" is defined in the statute as a finding that basic county services, including public safety, could not be maintained. The county's determination was reached by applying an existing rule to existing facts. As such, it was a quasi-judicial decision. The standard of review for a quasi-judicial determination is an independent examination of the proceedings to determine if the agency action has been arbitrary or capricious. Therefore, the substantial evidence standard used by the trial court in this case was incorrect since the action was not quasi-legislative. The trial court found the action was quasi-judicial, but applied the wrong standard of review. The failure of the trial court to apply the appropriate standard precluded review of the merits of the appeal. The matter was remanded for reconsideration. To guide the trial court in its review, it was also held that the trial court and the Commission had not erred in construing Section 17000.6.
        Goff v. Commission on State Mandates, C.A. 3rd, No. C022434, filed November 25, 1997, by Sparks, J.; Blease, J., concurring and dissenting.
        The full text of this case appears in 97 DJ D.A.R. 14371, November 28, 1997.