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Fullerton Joint Union High School Dist. v. State Bd. of Education

Fullerton Joint Union High School Dist. v. State Bd. of Education

Supreme Court of California

December 2, 1982

L.A. No. 31415

Opinion

 [*784]  [**170]  [***400]    The community of Yorba Linda has its own elementary school district, but is part of the Fullerton Joint Union High School  [***401]  District (Fullerton HSD). The State Board of Education (State Board) approved a plan (the Plan) to [****2]  create a new Yorba Linda  [**171]  Unified School District 1 and transfer responsibility for high school education of Yorba Linda students from the Fullerton HSD to the new district. The State Board directed that the proposal be submitted for approval in an election limited to the residents of Yorba Linda.

Fullerton HSD petitioned for mandate to prevent the election. The trial court upheld portions of the State Board's decision, but held invalid other portions, including the limitation of the franchise to Yorba Linda residents, and accordingly barred the election. Both parties appealed.

The appeal presents three issues: (1) Did the State Board comply with the requirements of Education Code section 4200, which specifies the conditions which must be met before the State Board authorizes the creation of a new school [****3]  district? (2) Is the State Board's decision invalid for noncompliance with the California Environmental Quality Act (Pub. Resources Code, § 21050 et seq.)? (3) Does the State Board's decision limiting the vote to Yorba Linda residents deny the equal protection of the laws to other residents of the Fullerton HSD?

With respect to the first issue, the parties agree that ] a reviewing court may inquire only whether the State Board's decision was arbitrary, capricious, or entirely lacking in evidentary support; applying that standard of review, we find that the State Board's decision complied with section 4200. We conclude, however, that the State Board's failure to undertake a threshold environmental study violated the California Environmental Quality Act, and that its limitation of the electoral franchise was unconstitutional.

1. Statement of facts.

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32 Cal. 3d 779 *; 654 P.2d 168 **; 187 Cal. Rptr. 398 ***; 1982 Cal. LEXIS 247 ****

FULLERTON JOINT UNION HIGH SCHOOL DISTRICT, Plaintiff and Appellant, v. STATE BOARD OF EDUCATION, Defendant and Appellant

Prior History:  [****1]  Superior Court of Orange County, No. 275518, Robert P. Kneeland, Judge.

Disposition: The judgment of the superior court is reversed and the cause remanded with directions to modify the judgment in conformity with the views expressed herein. Since the modified judgment will afford Fullerton HSD substantially the relief it seeks, it shall recover its costs on appeal.

CORE TERMS

residents, election, voters, annexation, strict scrutiny, enrollment, cases, reorganization, voting, approve, school district, unified school district, classification, franchise, secession, segregation, geographic, referendum, noncity, new district, high school, trial court, environmental, municipal, constituent, charter, percent, entity, real property, capricious

Education Law, Departments of Education, State Departments of Education, Authority of Departments of Education, Administrative Law, Judicial Review, Standards of Review, Arbitrary & Capricious Standard of Review, Governments, State & Territorial Governments, Elections, Remedies, Mandamus, State Boards of Education, Agency Rulemaking, State Proceedings, Administration & Operation, Elementary & Secondary School Boards, Authority of School Boards, School Districts, School District Alterations, Civil Procedure, Writs, General Overview, Reviewability, Factual Determinations, Formal Adjudicatory Procedure, Hearings, Local Governments, Financial Liabilities, School Funding, Bonds & Other Indebtedness, Gender & Sex Discrimination, Title IX, Scope of Title IX, Racial Discrimination, Desegregation, Faculty & Staff, Environmental Law, Natural Resources & Public Lands, National Environmental Policy Act, Abuse of Discretion, Business & Corporate Law, Duties & Liabilities, Causes of Action & Remedies, Burdens of Proof, Substantial Evidence, Legislation, Statute of Limitations, Governmental Entities, Time Limitations, Constitutional Law, Equal Protection, Standards of Review, Appeals, Boundaries