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Bd. of Supervisors v. McMahon - 219 Cal. App. 3d 286, 268 Cal. Rptr. 219 (1990)

Rule:

Trial courts should evaluate two interrelated factors when deciding whether or not to issue a preliminary injunction. The first is the likelihood that the plaintiff will prevail on the merits at trial. The second is the interim harm that the plaintiff is likely to sustain if the injunction were denied as compared to the harm that the defendant is likely to suffer if the preliminary injunction were issued.

Facts:

County voters approved a measure providing that (1) county officials were prohibited from the use of any local funds in programs administered by the county department of welfare; and (2) county board of supervisors could provide local funds for the administration of services not to exceed the maximum amount of welfare funds utilized in a specified fiscal year. In the specified year, the state had paid virtually 100 percent of the nonfederal share of the county's aid to families with dependent children (AFDC) grants-in-aid program. The state Department of Social Services petitioned for a writ of mandate and sued for injunctive relief against the county, contending that the measure violated state law and seeking to compel the county to continue to fund the AFDC program in the amount that state law required. On the same day, the county sued the state for declaratory and injunctive relief, asserting that the measure was valid and seeking to compel the state to fund entirely the nonfederal portion of the county's AFDC grants. The trial court consolidated the actions. It voided the measure as in conflict with state law on a matter of statewide concern, and it ultimately entered a judgment in the department's action directing a writ of mandate to issue. The judgment commanded the county to comply with state law on the funding of all welfare programs irrespective of the provisions of the measure. However, the trial court also considered the county's complaint outside of the context of the measure. After concluding that the county was likely to prevail on the merits and that the balance of hardships favored the county, the trial court issued a preliminary injunction ordering the state to fund entirely the county AFDC program.

Issue:

Taking into consideration the circumstances at hand, was it proper for the trial court to issue a preliminary injunction ordering the state to fund entirely the county AFDC program?

Answer:

No.

Conclusion:

The Court reversed the injunction, remanded to the trial court, and held that the trial court had abused its discretion when it issued the injunction because there was not sufficient evidence that respondent county would prevail in its claim against appellant state on constitutional grounds or on the theories of home rule or impossibility of performance. The Court held that respondent could not challenge appellant's statutory scheme for fundings on due process grounds because political subdivisions of a state could not challenge the validity of a state statute under the U.S. Const. amend. XIV, and because respondent had no property interest in its revenues. The Court furthermore held that Cal. Const. art. XVI, § 11 allowed the legislature to reimburse counties, but did not require it. According to the Court, the state legislation on matters of statewide concern did not implicate home rule rights and local government remained subject to state law. The Court held that there was not sufficient evidence of respondent's impossibility theory because it could raise revenues and that the level of service decisions belonged with the electorate, not the officials.

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