County of Riverside v. Superior Court

GEORGE, C. J., Concurring.—

I agree that the legislation before us is constitutionally impermissible in light of article XI, section 11, subdivision (a), of the California Constitution (article XI, section 11(a)), which prohibits the Legislature from delegating “to a private person or body” a county’s power to “perform municipal functions.” In my view, however, the majority should base its decision solely upon that relatively narrow constitutional provision, and need not and should not reach out to decide the distinct and potentially much more far-reaching question whether the legislation also violates article XI, section 1, subdivision (b), of the California Constitution (article XI, section 1(b)), which provides simply and generally that “[t]he governing body [of a county] shall provide for the number, compensation, tenure, and appointment of employees.” As I shall explain, the issue whether the general “home rule” provisions of article XI, section 1(b) preclude the Legislature from adopting the legislation at issue presents a much closer question than the majority acknowledges, and I believe that traditional principles of judicial restraint should lead the court to refrain from prejudging that broader constitutional issue when there is a narrower and fully adequate alternative ground upon which to rest its decision. Accordingly, I cannot join the majority opinion.

I

Article XI, section (l)(b), provides in relevant part: “The Legislature shall provide for county powers, an elected county sheriff, an elected district attorney, an elected assessor, and an elected governing body in each county. . . . The governing body shall provide for the number, compensation, tenure and appointment of employees.” (Italics added.)

*297The majority states that the language of article XI, section (l)(b) “is quite clear and quite specific: the county, not the state, not someone else, shall provide for the compensation of its employees” (maj. opn., ante, at p. 285), and concludes that the legislation in question—Senate Bill No. 402 (1999-2000 Reg. Sess.) (enacting Code Civ. Proc., § 1299 et seq.) (hereafter Senate Bill 402)—conflicts with this language because it “compels the county to enter into mandatory arbitration with unions representing its employees, with the potential result that the arbitration panel determines employee compensation.” (Maj. opn., ante, at p. 285.)

In my view, the issue is not nearly as simple or clear-cut as the majority suggests. Although article XI, section (l)(b) gives all counties (including noncharter counties) the authority to control the appointment and compensation of their own employees (prior to 1933, the Legislature exercised that authority over the employees of noncharter counties), other sections of article XI provide that charter counties and charter cities have similar or even broader authority to control the appointment, compensation, and dismissal of their employees. (See Cal. Const., art. XI, §§ 4, subd. (f), 5, subd. (b)(4).) Despite these explicit constitutional provisions establishing broad home rule authority of charter counties and charter cities over their own public employees, over the last half-century the Legislature has enacted a host of laws that govern various aspects of the labor relations of local public entities, and numerous cases have upheld the right of the state to enact such legislation—which takes precedence over contrary rules established by local entities.

For example, the California Fair Employment and Housing Act (Gov. Code, § 12900 et seq.) prohibits counties and other local entities (along with most other employers) (Gov. Code, § 12926, subd. (c)) from discriminating in employment on the basis of the categories enumerated in the act, and the provisions of that act—for example those barring discrimination on the basis of disability or marital status—obviously limit a local entity’s authority over the appointment or tenure of its employees. Perhaps most relevant to the present case is the Meyers-Milias-Brown Act (Gov. Code, § 3500 et seq.) (MMB Act), which places upon local entities the obligation to meet and confer in good faith with their employees on wages and other conditions of employment, and which grants public employees a variety of remedies to enforce such protections. As the majority recognizes, in People ex rel. Seal Beach Police Officers Assn. v. City of Seal Beach (1984) 36 Cal.3d 591 [205 Cal.Rptr. 794, 685 P.2d 1145], this court specifically upheld the validity of the MMB Act as applied to a charter city, concluding that in light of the statewide concern addressed by the act—the establishment of “[f]air labor practices, uniform throughout the state” (id. at p. 600)—application of the act did not violate the home rule provisions of California Constitution, *298article XI, section 5, subdivision (b). Of course, the majority does not suggest that the provisions of article XI, section 1(b)—setting forth the home rule authority of noncharter counties—place any greater restrictions on the Legislature’s authority than the even broader constitutional home rule provisions applicable to charter counties and charter cities.

Once it is recognized that the provisions of article XI, section 1(b) do not preclude the Legislature from promulgating a detailed collective bargaining regime that counties are required to follow in negotiating over compensation with all of their employees—the type of structure set forth in the MMB Act—it seems evident that the question whether the legislation at issue in this case violates article XI, section 1(b), is not as clear as the majority suggests. Although the majority asserts emphatically that “Senate Bill 402 is not merely procedural; it is substantive” (maj. opn., ante, at p. 289), that characterization of the legislation is hardly self-evident. In enacting Senate Bill 402, the Legislature did not undertake itself to set the compensation for county firefighters or police officers, but instead prescribed a dispute resolution procedure that is to be employed when the county and its firefighters or police officers are unable to reach agreement on economic issues that fall within the “meet and confer” requirement of the MMB Act. Furthermore, although the procedure set forth in the act calls for binding arbitration, the particular form of binding arbitration prescribed by the act does not afford the arbitrators free rein to resolve the dispute by setting compensation at whatever level the arbitrators deem appropriate. Instead the act limits the arbitrators’ discretion to choosing between the “last best offer” of each of the parties on each unresolved issue. (Code Civ. Proc., § 1299.6.)

It is true, of course, that the binding arbitration procedure established in Senate Bill 402 impinges directly upon the county’s general authority to retain the last word on employee compensation. But it is not at all clear that this circumstance is necessarily fatal to the validity of state legislation under article XI, section 1(b). As noted above, the relevant language of this constitutional provision provides that “[t]he governing body [of the county] shall provide for the number, compensation, tenure, and appointment of employees.” (Ibid., italics added.) Thus, under article XI, section 1(b), a county’s constitutionally granted authority over the compensation of its employees appears no greater than the county’s authority over the appointment or tenure of its employees. Under the California Fair Employment and Housing Act (FEHA), the Fair Employment and Housing Commission (FEHC) is granted the authority to resolve a claim that a county has engaged in unlawful employment discrimination in the appointment or dismissal process (Gov. Code, § 12960 et seq.), and a decision of the FEHC against the county clearly has the effect of “trumping” the authority the county *299otherwise would have to refuse to appoint or dismiss a person on the basis, for example, of his or her marital status or sexual orientation. (See Gov. Code, § 12940.) The circumstance that the FEHC has the authority in such instances to displace the ultimate decision that a county otherwise would be empowered to make regarding the appointment or tenure of a particular applicant, however, never has been viewed as casting any constitutional doubt on the application of the FEHA to counties or other local public entities. If the state properly may impinge upon a county’s power to appoint or dismiss employees in order to serve the statewide concern of protecting employees from discrimination, it is not immediately apparent why the state, to serve the statewide concern of protecting the public from the widespread risks posed by strikes by firefighters or police officers, may not similarly impinge upon a county’s authority to have the last word on employee compensation.

For these reasons, I find the question whether Senate Bill 402 violates article XI, section 1(b) to be much closer and more difficult than the majority acknowledges.

II

Moreover, as noted at the outset, there is no need for the majority to resolve the question whether Senate Bill 402 violates article XI, section 1(b), in light of the majority’s conclusion that Senate Bill 402 violates the entirely distinct provisions of article XI, section 11(a). The majority’s holding under article XI, section 11(a) clearly is sufficient in itself to resolve this case. And because article XI, section 11(a) is a more focussed provision than article XI, section 1(b), and is directed at the particular “evil or mischief’ reflected in Senate Bill 402—which is a measure enacted by the Legislature delegating to a private body the power to perform a municipal function that otherwise would be performed by a county—that constitutional provision unquestionably provides a much narrower ground of decision than the broad and more general provisions of article XI, section 1(b).

Article XI, section 11(a) reads in full: “The Legislature may not delegate to a private person or body power to make, control, appropriate, supervise, or interfere with county or municipal corporation improvements, money, or property, or to levy taxes or assessments, or perform municipal functions.”

I agree with the majority’s conclusion that in enacting Senate Bill 402 the Legislature violated this provision by delegating to a private body (the arbitration panel) the power to perform a municipal function (establishing the level of compensation for certain county employees). Contrary to the *300argument of the Riverside Sheriffs Association, an arbitration panel cannot properly be viewed as a “public body” exempt from the restrictions of article XI, section 11(a), simply because the panel is empowered to perform a public function, because such reasoning would vitiate the fundamental purpose and scope of this constitutional provision. And I agree with the majority that the case of People ex rel. Younger v. County of El Dorado (1971) 5 Cal.3d 480 [96 Cal.Rptr. 553, 487 P.2d 1193] provides no support for the Riverside Sheriffs Association’s argument. The decisionmaking body to which governmental functions have been delegated in the present case—unlike the body in El Dorado—is not charged with the responsibility of taking into account statewide or regional concerns in making its decisions, but instead is granted the authority to decide a quintessentially local question.

Accordingly, I agree with the majority that—in view of the wording of article XI, section 11(a)—the Legislature may not compel an unwilling local public entity to submit a municipal function to binding arbitration by a private body.

Ill

By reaching out unnecessarily to rest its decision on the broad provisions of article XI, section 1(b), when a decision based upon the more focussed provisions of article XI, section 11(a) would suffice, the majority not only fails to heed traditional principles of judicial restraint, but also creates an unfortunate precedent that may improperly restrict the Legislature’s authority in the future to fashion a remedy for statewide or regional safety or health problems resulting from strikes or other labor-related actions of local public health or safety employees. Although article XI, section 11(a), prohibits the Legislature from enlisting a private arbitration panel to resolve a local police or firefighter labor conflict that threatens to endanger neighboring communities, that constitutional provision would not preclude the Legislature from granting a public body—perhaps like the Public Employment Relations Board (Gov. Code, § 3541)—the authority to review and resolve a local labor dispute that poses a significant risk to public safety or health beyond the borders of the local public entity. In my view, it is improper to prejudge the question of the validity or invalidity of such a legislative measure that is not before us, and we should avoid an unnecessarily broad holding that may have the effect of prematurely resolving that question and restricting the options available to the other two branches of government.