HomeMy WebLinkAboutAgenda Report - January 7, 2009 E-07AGENDA ITEM 6 of 77
CITY OF LODI
COUNCIL COMMUNICATION
iM
AGENDA TITLE: Request Authorization for Joinder in Amicus Brief in Support of City of Irvine in the
case of City of Irvine v. Southern California Association of Governments. California
Court of Appeal, Fourth Appellate District, Division 3
MEETING DATE: January 7,2009 City Council Meeting
PREPARED BY: City Attorney's Office
RECOMMENDED ACTION: That the City Council authorize joining the Amicus Brief in the case
of CL of Irvine v. Southern California Association of Governments.
California Court of Appeal, Fourth Appellate District, Division 3
BACKGROUND INFORMATION: Amicus Briefs are filed in various actions, which involves matters of
wide-ranging concern to provide information and additional
argument to the Court in order to assist the Court in understanding
all of the issues and arrive at a conclusion.
In the Irvine case, the local Council of Governments assigned a fair housing percentage to Irvine under
the Regional Housing Needs Assessment (RHNA) process, that, as this Council can sympathize from
personal experience, Irvine's Council felt was disproportionate. Irvine challenged the assessment but the
trial court concluded it had no jurisdiction to hear the challenge. Irvine seeks Lodi's support in its appeal
to ensure that cities that dispute their RHNAAssessment can seek judicial review.
FISCAL IMPACT: None.
APPROVED:
Mair fCnS City Manager
Wdo
December 9,2008
City of Lodi
P.O. Box 3006
Lodi, CA 95241
BETH KROM, Mayor
F,11 11:x•
www.ci.irvine.ca.us
City of Irvine, One Civic Center Plaza, P.O. Box 19575, Irvine, CA 92623-9575 (949) 724-6233
!fie: Requestfar Joinder in Amicus Brief in Support of City of Irvine
City of Irvine v. Southern California Association of Governments
California Court of Appeal, Fourth Appellate District, Division 3
Dear Honorable Mayor:
Irvine is seeking support from those cities that feel, as we do, that regardless of
the merits of the underlying challenge to the RHNA process, cities deserve their
day in court when a council of governments violates State law. Thank you in
advance for taking the time to read and consider this letter, which deals with the
extremely important subject of the ability of cities to have their "day in court" to
protect and preserve local control over the content of their general plans and,
more specifically, their housing elements.
Byway of background,the City of Irvine ("Irvine") had filed a petition for writ of
mandate in the Orange County Superior Court to challenge the adoption by the
Southern California Association of Governments ("SCAG") final allocation plan
under the regional housing needs assessment ("RHNA) for the current housing
cycle. SCAG filed a motion asking the Orange County Superior Court to dismiss
Irvine's lawsuit on the ground that courts have no jurisdiction to review and
adjudicate the validity of determinations rendered by regional councils of
government related to the RHNA process.
Acknowledging that there is no expressed statutory provision and that the
decision on the jurisdictional issue was a difficult call, the Superior Court
dismissed Irvine's lawsuit. In addition, the Superior Court expressed that there
was "no doubt that this issue will be revisited by the appellate courts." Irvine has
appealed the dismissal of its lawsuit, and the jurisdictional issue is currently
before the California Court cfAppeal for the Fourth Appellate District, Division 3.
(As an aside, there also are two appeals on the identical issue pending before
the Second Appellate District with regard to SCAG allocations that have been
challenged by the Cities of La Mirada and Palmdale.)
PRINTED ON RECYCLED PAPER
December 9,2008
Page 2
Although the facts of Irvine's lawsuit are not relevant to our appeal, it is worth
noting that SCAG allocated Irvine over 43% of the entire Orange County regional
housing need, which hardly constitutes a "fair share" allocation. Irvine's lawsuit
claims that this allocation constitutes an abuse of discretion and violates various
State mandates and requirements in connection with the RHNA process. While
we regret having to take this matterto the courts, it is the only jurisdiction of
reviewthat we have available to us. The State has ceded authority to SCAG and
our appeal to SCAG and request for reallocation was denied.
While issues of RHNA allocation are debated by cities throughout the state,
Irvine has a long history of embracing balanced development, including the
provision of affordable housing. That said, what city could be expected to plan for
almost a 50 percent increase in its housing stock, in Irvine's case 35,000 new
housing units within one cycle?
When Irvine learned that SCAG was seeking support for its position on the
jurisdictional issue from other regional councils of governments and/or the
California Association of Councils of Governments, Irvine submitted a formal
requestto the Legal Advisory Committee of the League of California Cities for
authorization of an amicus ("friend of the court") brief addressing the following:
"The legal issue is solely and simply whether a court has jurisdiction to hear a
mandamus challenge brought by a city or county against a council of
governments for official action taken during the RHNA process."
The Legal Advocacy Committee considered the request and approved the
preparation and filing of an amicus brief on behalf of the League. Despite this
recommendation, on November 22, 2008, the California League of Cities Board
voted to rescind the Legal Advocacy Committee's decision and instead remain
neutral in the litigation. Individual cities are free to participate in amicus support if
they wish to do so which is why I am writing and requesting such support.
The disposition of our appeal has serious implicationsfor all California cities.
Currently, there is no forum In the courts for a cityto-seek iefief in the eventthe
RHNA process fails to comply with State -mandated requirements. If allowed to
become the law of the State, the holding in the Irvine lawsuit could have
disastrous consequences for all cities with regard to determinations made by
regional councils of government. Furthermore, it could be used to establish
precedentwith respectto other obligations imposed on cities by Regional
Councils and the state.
It is Irvine'sview that SCAG's position flies in the face of traditional notions of the
separation of powers and the right to judicial review. Checks and balances are a
foundation of our democracy. Cities are charged with the responsibility to carry
out its governmental activities in accordance with applicable laws and
regulations, and to be held accountable in the courts if they fail to do so. While
December 9,2008
Page 3
SCAG asserted to the League's Board of Directors that a reduction in Irvine's
allocation under the RHNA will result in a reallocation of residential units to other
jurisdictions within SCAG, no case law supports this position. Irvine was keenly
aware of this concern and specifically did not seek a reallocation of units to other
jurisdictions when we filed our lawsuit.
What is before the Court of Appeal now is simply whether cities have a right to
seek redress from an independenttribunal if a council of governments violates
the RHNA process. That is, the merits of Irvine's challenge to the process are not
being adjudicated. A published court decision that prohibits judicial review of
decisions of councils of governments concerning RHNA allocations severely
impacts local control over housing elements and local planning. Cities should
also be concerned about other local planning authority. If cities are prevented
from seeking judicial review of administrative procedures that apply to housing
element law, councils of governments can be expected to extend that holding to
other areas of regional planning (e.g., the Regional Transportation Plan) that
ultimately affect city planning.
In closing, If your city has an interest in preserving the right of all cities to seek
judicial review under such circumstances and support Irvine's position through
no -cost participation in an amicus brief, please contact as soon as possible Bill
Ihrke at Rutan & Tucker, LLP, lead counsel for the City of Irvine on this case, at
bihrkee-rutan.com or 714-338-1863. If you would like to speak to me directly,
please call me at (949) 724-6233.
Sincerely,
111�1 i4*�',
BETH KROM
Mayor