Hastings Constitutional Law Quarterly


Helen Luu Chou


In December 2011, the California Supreme Court in California Redevelopment Association v. Matosantos upheld AB 1X 26-a bill eliminating redevelopment agencies in California. Even though redevelopment officially ended with Matosantos, discussion concerning the state of redevelopment has since been revived. The purpose behind the dissolution of redevelopment agencies was to fund special districts in a time of financial crisis, but what instead followed was dissension within California as cities and counties strongly opposed the dissolution of redevelopment and instead filed lawsuits challenging the constitutionality of AB 1X 26, and its subsequent "clean up" bill, AB 1484. Moreover, the redevelopment wind-up process has been anything but clean, as cities fight with the State over what redevelopment obligations prior to dissolution should still be honored by the State. As a result, over 150 lawsuits have been filed in California courts challenging redevelopment dissolution on many different legal grounds.

This Note looks at the state of redevelopment after the California Supreme Court's decision in Matosantos. This Note will contextualize the current redevelopment debate by looking at the history of redevelopment and the events leading up to the passage of AB 1X 26, the redevelopment dissolution bill. This Note will also describe the aftermath of Matosantos, most notably the problems that dissolution created for the cities in light of AB 1X 26 and the subsequent "clean up" bill, AB 1484. The Note will also survey the lawsuits that have been filed against the State concerning redevelopment, and its legal and constitutional arguments. Finally, this Note will analyze the state of redevelopment in California going forward by evaluating the legal arguments posed by both sides in the redevelopment debate.