Hastings Constitutional Law Quarterly


On January 20, 2011, California Governor Jerry Brown issued a proclamation reaffirming the fiscal emergency that had been declared by his predecessor administration. In response to the fiscal emergency, the state Legislature enacted two measures that were intended to stabilize school funding by reducing or eliminating the diversion of property tax revenues from school districts to the state's community redevelopment agencies. The California Redevelopment Association, the League of California Cities, and other affected parties immediately brought suit, seeking direct relief from the Supreme Court of California on grounds that the statutes violated various portions of the California Constitution.

This note analyzes the constitutional significance of California Redevelopment Association v. Matosantos. It argues that the Matosantos decision interpreted the California Constitution to reaffirm the view that municipal governments are mere agents of the state. Furthermore, in connection with that power structure, the Matosantos decision may also be seen as another reminder of the trouble that frequent constitutional amendment can lead to. Lastly, this note contends that however redevelopment occurs in California following Matosantos, absent a crystalclear constitutional directive to the contrary, the state retains its plenary authority to work paradigm shifts in the local landscape should it be necessary.