L.A. County Employees Retirement Association v. County of L.A.
CourtCalifornia Supreme Court
Date FiledAugust 3, 2026
DocketS286264
StatusPublished
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Full Opinion
IN THE SUPREME COURT OF
CALIFORNIA
LOS ANGELES COUNTY EMPLOYEES RETIREMENT
ASSOCIATION,
Plaintiff and Appellant,
v.
COUNTY OF LOS ANGELES et al.,
Defendants and Respondents.
S286264
Second Appellate District, Division Seven
B326977
Los Angeles County Superior Court
21STCP03475
August 3, 2026
Justice Corrigan authored the opinion of the Court, in which
Chief Justice Guerrero and Justices Kruger and Simons*
concurred.
Justice Groban filed a dissenting opinion, in which Justices Liu
and Evans concurred.
__________________________
* Associate Justice of the Court of Appeal, First Appellate
District, Division Five, assigned by the Chief Justice pursuant
to article VI, section 6 of the California Constitution.
LOS ANGELES COUNTY EMPLOYEES RETIREMENT
ASSOCIATION v. COUNTY OF LOS ANGELES
S286264
Opinion of the Court by Corrigan, J.
This case presents two related issues about the job
classification and salary-setting authority granted to public
pension boards and county boards of supervisors.
The first issue concerns power granted by the California
Constitution giving public pension retirement boards “plenary
authority and fiduciary responsibility for investment of moneys
and administration of the system.” (Cal. Const., art. XVI, § 17
(section 17).) The question involves the scope of authority
granted. Specifically, does that constitutional authority over
the management of fund assets and delivery of benefits extend
more broadly to empower a retirement board to unilaterally set
civil service classification and salary levels for system
employees?
The second issue concerns the statutory authority of
county governments and retirement boards operating under the
1937 County Employees Retirement Law. (CERL; Gov. Code,
§ 31450 et seq.)1 That inquiry addresses whether, apart from
the Constitution, the CERL statutes separately grant county
retirement boards the power to set classification and salary
levels and compel county boards of supervisors to implement
1
All undesignated statutory references are to the
Government Code.
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LOS ANGELES COUNTY EMPLOYEES RETIREMENT ASSN. v. COUNTY
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Opinion of the Court by Corrigan, J.
these retirement board decisions in the county’s salary
ordinance.
The Los Angeles County Employees Retirement
Association (LACERA) is a retirement system operating under
the CERL statutory scheme. It petitioned for a writ of mandate
compelling the County of Los Angeles (County) to implement its
classification and salary decisions for certain staff positions.
The trial court denied the writ but the Court of Appeal reversed,
concluding retirement boards have the final authority to decide
classification and salary setting. In so holding, the court
disagreed with Westly v. Board of Administration (2003) 105
Cal.App.4th 1095, 1110 (Westly), which had construed the
constitutional authority of retirement boards more narrowly.
We conclude Westly’s narrower construction was correct.
Considered as a whole, the relevant constitutional and statutory
provisions create a system of cooperative responsibility between
retirement boards and governing bodies on issues related to
employee classification and compensation. There is no
indication that either the Legislature or the voters intended to
upset that balance by leaving these decisions to retirement
boards alone. We also reject the related argument that CERL
imposes a mandatory duty on counties to automatically
implement retirement board decisions on classification and
salary setting. Instead, we hold that, while CERL grants
retirement boards the power to “appoint,” or hire, necessary
personnel (§ 31522.1), county governments retain final
authority over their civil service classification and salaries.
Such decisions are subject to judicial review for abuse of
discretion, however, and a writ of mandate may issue if the
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Opinion of the Court by Corrigan, J.
county unreasonably delays or withholds its approval of the
retirement board’s recommendations.
I. BACKGROUND
Resolving the questions on appeal brings into play the
intricate legal framework governing county employment and the
powers conferred upon retirement boards.
A. Legal Framework
1. County Employment and Civil Service
The general rule is that governing bodies of California
counties have the constitutional and statutory power to “provide
for the number, compensation, tenure, and appointment of”
their employees. (Cal. Const., art. XI, § 1, subd. (b); see Gov.
Code, § 25300; see also County of Riverside v. Superior Court
(2003) 30 Cal.4th 278, 285 (County of Riverside).) In counties
that have adopted a charter for their governance, the details of
county employment are set by ordinance enacted by the county’s
governing body. (Cal. Const., art. XI, § 4, subd. (f).)
Los Angeles is a charter county governed by a Board of
Supervisors. (L.A. County Charter, § 2.) The County’s charter
establishes a civil service system and designates all employment
positions as “unclassified” or “classified.” (Id., §§ 30, 33.)
Elected officials, heads of County agencies, and other identified
executive positions are “unclassified,” with all remaining
positions being “classified.” (Id., § 33.) By charter, the County
“has a formal civil service system . . . for filling classified
positions and fixing the salary and benefits of classified
employees.” (Holmgren v. County of Los Angeles (2008) 159
Cal.App.4th 593, 602 (Holmgren).) Civil service rules exist to
ensure fairness in the government workplace. They do so by
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Opinion of the Court by Corrigan, J.
making access to government employment broadly and fairly
available under clear criteria for employment and advancement.
They are also designed to prevent favoritism or corruption by
requiring that all employees are uniformly paid based on their
qualifications, job duties, and performance. (See Almassy v. Los
Angeles County Civil Service Com. (1949) 34 Cal.2d 387, 404
(Almassy); Los Angeles County Employees Assn. v. Superior
Court (2000) 81 Cal.App.4th 164, 169–170.)
The County’s civil service rules establish job
classifications, hiring qualifications, criteria for recruiting and
ranking candidates, and policies and systems for evaluating
employees. (L.A. County Charter, § 35.) Here, as the Court of
Appeal noted, the term “ ‘classification’ ” means “ ‘ “a set of
individual positions, suitable for similar treatment with respect
to pay, examination procedures, and work assignments that are
clustered or grouped by virtue of the similarity of the nature of
work performed, the level of job complexity and responsibility
required, the knowledge, skill and ability requirements, and the
working conditions.” ’ ” (Los Angeles County Employees
Retirement Assn. v. County of Los Angeles (2024) 102
Cal.App.5th 1167, 1186 (Los Angeles County Retirement).) The
County’s Chief Executive Officer is responsible for classifying all
employment positions and recommending salary ranges to the
Board of Supervisors consistent with the policy of “ ‘equal pay
for equal work.’ ” (Ibid.; see California Attorneys, etc. v.
Schwarzenegger (2009) 174 Cal.App.4th 424, 436 (California
Attorneys).) Once approved, these decisions are included in the
County’s annual salary ordinance.
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2. Laws Regulating County Retirement Systems
a. CERL
In 1937, the Legislature enacted CERL, which established
a comprehensive set of rules that counties may adopt to govern
their public employee pension systems. “Each county system is
administered by its own retirement board, which is tasked with
implementing CERL’s provisions.” (Alameda County Deputy
Sheriff’s Assn. v. Alameda County Employees’ Retirement Assn.
(2020) 9 Cal.5th 1032, 1052 (Alameda County).) Generally, the
goal of a public pension plan “is to ensure payment of all vested,
promised benefits to members, both those currently retired and
those who will retire in the future.” (Imperial County Sheriff’s
Assn. v. County of Imperial (2023) 87 Cal.App.5th 898, 903.)
These benefits are funded “from three sources: employer
contributions, employee contributions, and investment earnings
and appreciation on the system’s trust fund.” (Ibid.) In a CERL
system, the employer is typically the county itself, or a political
subdivision or district within the county. (Traub v. Board of
Retirement (1983) 34 Cal.3d 793, 798 (Traub).) Twenty counties
have CERL pension plans. (Alameda County, at p. 1055.) The
other 38 counties operate independent plans or contract with the
state’s Public Employee Retirement System (CalPERS; § 20000
et seq.). (Alameda County, at p. 1055.)
Shortly after CERL was enacted, the Los Angeles County
Board of Supervisors passed an ordinance opting into the CERL
system and adopting “all and every one of” its provisions. (L.A.
County Code, § 5.20.010; see Los Angeles County Retirement,
supra, 102 Cal.App.5th at p. 1186; Holmgren, supra, 159
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Opinion of the Court by Corrigan, J.
Cal.App.4th at p. 603.)2 Ten years after opting into CERL, the
County established LACERA as a CERL system. (Los Angeles
County Retirement, at pp. 1186–1187; Howard Jarvis
Taxpayers’ Assn. v. Board of Supervisors (1996) 41 Cal.App.4th
1363, 1373.) LACERA holds, invests, and administers the
pensions and benefits of member employees. (Weber v. Board of
Retirement (1998) 62 Cal.App.4th 1440, 1442 (Weber).) “Subject
to a few exceptions for seasonal and part-time employees, all
classified [C]ounty employees are automatically enrolled in”
LACERA by operation of law. (Holmgren, at p. 603; see
§§ 31550–31552.)
2
That ordinance makes all of CERL’s provisions binding
upon the parties here. It states: “The board of supervisors of
the county of Los Angeles, state of California, accepts the
provisions of an Act of the Legislature of the state of California,
entitled ‘An act to provide for the creation, establishment, and
adjustment with other systems, of a retirement system for
employees of the several counties and districts as defined
herein, and attaches of municipal courts, consisting of
retirement compensation and death benefits,’ approved June 30,
1937, being Chapter 677 of the Statutes of 1937 [CERL], and
said board of supervisors does hereby, by reference adopt and
incorporate all and every one of the provisions of said Act of the
Legislature as a part of and applicable to, and make all and
every one of said provisions a part of and applicable to, the
system and schedules of compensation of all officers and other
persons employed by the county whose compensation is fixed by
the board of supervisors of the county and whose compensation
is paid by the county, and all employees and officers of the
county of Los Angeles now or hereafter established by ordinance
of the board of supervisors, who are or may hereafter be eligible
to the benefits of any retirement system under the provisions of
said Act.” (L.A. County Code, § 5.20.010.)
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Opinion of the Court by Corrigan, J.
LACERA has both a “board of retirement” (§ 31520) and a
“board of investments” (§ 31520.2). The Board of Retirement
administers the system, while the Board of Investments
manages LACERA’s investment and actuarial policies. (Los
Angeles County Retirement, supra, 102 Cal.App.5th at p. 1187;
see Weber, supra, 62 Cal.App.4th at p. 1442.) In a CERL system,
county retirement boards do not design individualized pension
plans but instead implement the design enacted by the
Legislature. (Alameda County, supra, 9 Cal.5th at pp. 1066–
1067.) A retirement board’s primary duties are to protect the
system’s assets through investment decisions and actuarial
adjustments, to calculate and deliver benefits and services to
system members, and to decide members’ claims. (89
Ops.Cal.Atty.Gen. 152, 158 (2006).)
The complex interrelationship between a CERL
retirement system and county government is regulated by the
Government Code. CERL requires that the county treasurer sit
on the retirement board (§§ 31520, 31520.1) and investment
board (§ 31520.2). In addition to the county treasurer, half of
the remaining members of a CERL retirement board or
investment board are appointed by the county’s board of
supervisors.3 Accordingly, the managerial as well as “the
financial relationship between the county and the retirement
system is a close one.” (Corcoran v. Contra Costa County
Employees Retirement Bd. (1997) 60 Cal.App.4th 89, 94
3
In counties with five-member retirement boards, two
members are appointed by the county. (§ 31520.) In counties
with nine-member retirement boards, or with investment
boards, four members are appointed by the county. (§§ 31520.1,
31520.2.)
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Opinion of the Court by Corrigan, J.
(Corcoran); see, e.g., §§ 31590, 31595.1.) Also, as relevant here,
a retirement system’s staffing decisions are guided by county
requirements. CERL authorizes retirement boards to “appoint
such administrative, technical, and clerical staff personnel as
are required to accomplish the necessary work of the boards,”
but these appointments must “be made from eligible lists
created” under the county’s civil service rules. (§ 31522.1.)
Under CERL, these staff members “shall be county employees
. . . subject to the county civil service or merit system rules” and
must be included in the county’s salary ordinance. (§ 31522.1.;
see Corcoran, at p. 94.) Retirement boards may also appoint
executive personnel, including senior administrators, chief
investment and legal officers, and their deputies. These
executive personnel are also considered county employees, but
they serve at the pleasure of the boards and are not subject to
county civil service or merit system rules. (§§ 31522.2–31522.4.)
Despite these ties to county government, a CERL
retirement board is not a mere agent of the county. A retirement
board is not in privity with the county for preclusion purposes
because it is “an independent entity” (Traub, supra, 34 Cal.3d
at p. 798) with a “distinctive identity, constituency and
interests” (id. at p. 799). The board has “exclusive control” over
investments of the retirement fund, which it must manage for
the sole purposes of “providing benefits to participants . . . and
their beneficiaries and defraying reasonable expenses of
administering the system.” (§ 31595.) CERL also requires that
retirement boards “annually adopt a budget covering the entire
expense of administration of the retirement system, which
expense shall be charged against the earnings of the retirement
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Opinion of the Court by Corrigan, J.
fund.” (§ 31580.2, subd. (a).)4 In other words, all costs of
administering the retirement system, including staff
compensation, are paid from the retirement fund’s investment
earnings and not directly from county funds.
b. Section 17
The Constitution addresses the powers and
responsibilities of public pension boards in section 17 of Article
XVI, which covers Public Finance. Section 17 applies not just to
county-level retirement boards, but to the retirement board of
any public pension or retirement system operating in the state.
A 1984 ballot initiative, Proposition 21, amended section 17 to
make clear that public pension fund assets are held in trust.
(See O’Neal v. Stanislaus County Employees’ Retirement Assn.
(2017) 8 Cal.App.5th 1184, 1202 (O’Neal).) Voters later
expanded retirement boards’ authority by enacting Proposition
162, the California Pension Protection Act of 1992. This
initiative conferred upon retirement boards “plenary authority
and fiduciary responsibility for investment of moneys and
administration of the system, subject to” certain provisions.
(Cal. Const., art. XVI, § 17.) Proposition 162 specified that
retirement boards have “sole and exclusive fiduciary
responsibility over” pension fund assets and must “administer
the system in a manner that will assure prompt delivery of
benefits and related services to the participants and their
beneficiaries.” (Cal. Const. art. XVI, § 17, subd. (a).) It further
4
This requirement applies to all retirement systems with
appointed staff, including those with specific legislation making
their staff employees of the retirement system itself instead of
the county. (§ 31580.2, subd. (a); see §§ 31522.1, 31522.5,
31522.7, 31522.9, 31522.10, 31522.11.)
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provided that a retirement board’s fiduciary duty to participants
and beneficiaries is paramount, taking precedence over any
other duty. (Id., subd. (b).) The constitutional issue involved
here concerns the scope and application of Proposition 162’s
grant of authority.
B. Historical Relationship Between the Parties
LACERA manages the retirement fund for the County, for
the Los Angeles County Superior Court, and for several outside
districts. With a portfolio valued at over $72 billion and over
185,000 members and beneficiaries, it is the largest county
retirement system in the nation. In recent years, LACERA has
received approximately $3 billion annually from employee and
employer contributions and paid approximately $4 billion in
benefits. The $1 billion shortfall is paid from investment
earnings, which make up the great majority of LACERA’s
annual income.5
To manage this system, LACERA has more than 400
employees. Their compensation is LACERA’s largest
administrative expense. In each of the three years leading up
to this lawsuit, employee salaries and benefits comprised more
than three-quarters of total administrative costs. As CERL
requires (see § 31580.2, subd. (a)), LACERA maintains its own
budget, without County oversight. All administrative costs,
including salaries, are paid from LACERA’s investment
5
For example, in the fiscal year ending June 30, 2021,
nearly 85 percent ($15.63 billion) of LACERA’s total income
came from investment earnings. The remainder consisted of
contributions from employees ($761 million) and County
employers (approximately $1.95 billion).
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Opinion of the Court by Corrigan, J.
earnings. In July 1978, relying on sections 31522.1 and 31580.2
of CERL’s statutory framework, LACERA began hiring fund
management personnel and charging the expense against its
own budget. Previously, these fund management operations
had been handled by the County’s Treasurer and Tax Collector’s
Office and paid for from the County’s general fund.
Nearly 20 years later, in 1996, LACERA obtained a formal
legal opinion regarding the extent of the County’s authority over
the appointment of LACERA staff. LACERA’s external counsel
concluded section 31522.1 gave LACERA sole authority over
hiring, subject only to judicial review. Thus, counsel opined, the
Board of Supervisors was required to honor LACERA’s
classification and compensation decisions and include those
retirement board decisions in the County’s salary ordinance. At
the time, the County did not dispute counsel’s conclusions. It
removed LACERA employees from County collective bargaining
units and placed them into separate units governed by separate
memoranda of understanding.6
6
The dissent makes much of County Counsel’s 1996 letter
acquiescing in the legal opinion offered by LACERA’s retained
counsel. (See dis. opn. of Groban, J., post, at pp. 6, 8, 20, 33.)
From this letter and documents expressly referencing it, the
dissent projects a 40-year history of “shared understanding” (id.
at p. 2) in which the County deferred entirely to LACERA,
implementing its every classification and salary decision
without question. (See id. at pp. 33–34, 44.) The record does
not support this assertion. Indeed, it includes few specifics
about the parties’ dealings on these matters before 1996, when
LACERA retained outside counsel to research whether the
Board of Supervisors had a ministerial duty to implement
LACERA’s classification and salary decisions. It is unclear why
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Opinion of the Court by Corrigan, J.
Since these changes, LACERA has operated as an entity
that is closely related to, albeit distinct from, the County.
LACERA’s operational budget is not included in the County’s
budget. LACERA employees are subject to the County’s civil
service rules, although these rules are administered by
LACERA and not the County. LACERA personnel are assigned
to civil service classifications established by the Board of
Supervisors, but their classifications and payroll titles are
unique to LACERA and separate from Countywide
classifications and titles. The County administers LACERA’s
payroll, and LACERA uses some County resources for training
staff and developing personnel policies. LACERA employees are
eligible to participate in the County’s CERL retirement plan and
are offered the same fringe benefits, such as health care,
provided to County employees. LACERA holdings fund these
benefits, including the employer contribution for retirement.
C. This Dispute
After decades of cooperation, disagreements arose. In
2016 and 2017, based on the results of two internal personnel
reviews, the LACERA boards approved several new job
classifications and salary adjustments for information
technology, management, and administrative positions. In
accordance with the parties’ custom, LACERA asked the County
to implement these personnel decisions in its salary ordinance.
The County’s Chief Executive Officer agreed to some of the
requests but refused others, concluding the positions were “not
supported,” were not aligned with County classifications, or
seeking such an opinion would have been necessary if the
parties were in agreement.
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were beyond the salary range of comparable positions in the
County or in other counties’ retirement systems. In support of
these refusals, County Counsel Mary Wickham wrote an opinion
letter disavowing the County’s previous position and asserting
that LACERA lacked constitutional or statutory authority to
usurp the County’s control over the appointment and
compensation of County employees. Wickham’s opinion relied
on the text of article XVI, section 17 as interpreted in Westly. In
June 2018, the supervisors adopted a salary ordinance
consistent with the County Counsel’s views. LACERA did not
challenge the 2018 ordinance.
The following year, a new chief executive officer joined
LACERA and reviewed the organization’s needs. In June 2021,
LACERA sought County approval for three new positions and
adjustments to the classifications and salary levels for eight
existing positions. Several of these requests were for changes
the County had already refused in 2018. The County’s response
was again largely negative. It approved only one new position
(Deputy Chief, Investment Officer) at the salary level requested.
It approved a second new position (Information Technology
Manager II) but set a lower salary “based on internal alignment
considerations with comparable County classifications and
external salary data.” A third new position (Principal Staff
Counsel) was denied. The County also rejected all but one of
LACERA’s eight requested salary adjustments. The one
adjustment it granted was at a lower salary than requested.
In October 2021, LACERA challenged these actions by
seeking declaratory relief and a writ of mandate directing the
County to implement the classification and salary adjustments
it had denied. The case turned on whether LACERA or the
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Board of Supervisors had the power to set classifications and
salaries. The trial court denied relief. It interpreted Proposition
162 narrowly, relying on the analysis in Westly, supra, 105
Cal.App.4th 1095. Applying Westly, it determined that while
Proposition 162 gave LACERA “plenary authority” over fund
management and service delivery (Cal. Const., art. XVI, § 17),
the initiative did not confer new power on retirement boards to
set job classifications or salaries. The court further concluded
LACERA’s hiring power under CERL was subordinate to the
County’s constitutional and statutory authority to establish
classifications and compensation for all County employees. It
reasoned that section 31522.1 “ ‘permits LACERA to make
recommendations to the Board of Supervisors . . . , but the Board
of Supervisors does not have a ministerial duty to rubber stamp
those requests in a salary ordinance.’ ” (Los Angeles County
Retirement, supra, 102 Cal.App.5th at p. 1197, italics added.)
The Court of Appeal reversed, declining to follow Westly.
It applied Proposition 162’s phrase “plenary authority” broadly
to conclude that the initiative gave retirement boards complete
authority over “administration” (Cal. Const., art. XVI, § 17),
including the power to establish job classifications and salary
levels for the system’s employees. (Los Angeles County
Retirement, supra, 102 Cal.App.5th at pp. 1202–1204.) The
court also disagreed with the trial court’s analysis of the
relevant CERL statutes. (Los Angeles County Retirement, at
pp. 1218–1223.)
As noted, we granted review to resolve the conflict with
Westly and to clarify the scope of retirement boards’ authority
on these issues.
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II. DISCUSSION
“ ‘A traditional mandamus is sought to enforce a
nondiscretionary duty to act on the part of a court, an
administrative agency, or officers of a corporate or
administrative agency.’ [Citation.] ‘There are two requirements
essential to issuance of a writ of mandate under Code of Civil
Procedure section 1085: (1) the respondent [here, the County]
has a clear, present, and usually ministerial duty to act; and
(2) the petitioner [LACERA] has a clear, present, and beneficial
right to performance of that duty.’ ” (Pacifica Firefighters Assn.
v. City of Pacifica (2022) 76 Cal.App.5th 758, 765.) On review
from denial of a mandate petition, we defer to the trial court’s
factual findings if they are supported by substantial evidence
but independently review its rulings on questions of law.
(Professional Engineers in California Government v. Kempton
(2007) 40 Cal.4th 1016, 1032 (Professional Engineers).) This
case involves a purely legal question of which entity has the
ultimate authority to approve the classification and salary
decisions at issue. Accordingly, our review is de novo. (Ibid.;
Kavanaugh v. West Sonoma County Union High School Dist.
(2003) 29 Cal.4th 911, 916.)
The claims here are both constitutional and statutory in
nature. In resisting LACERA’s writ petition, the County relies
in part on constitutional provisions establishing what is
colloquially known as the “ ‘ “home rule” ’ ” doctrine. (County of
Riverside, supra, 30 Cal.4th at p. 286; see Cal. Const., art. XI,
§§ 1, subd. (b), 4, subd. (f).) The County asserts that, under the
home rule provisions, it has the constitutional authority to
appoint and fix the compensation of all County employees,
including those who work for LACERA. It contends this
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Opinion of the Court by Corrigan, J.
authority, as well as the collaborative relationships set out in
CERL, were not changed by the enactment of Proposition 162.
In sum, it urges that although LACERA has the statutory power
to appoint the staff needed to run the retirement system, the
County has the final say in deciding the classification and
compensation of these County employees.
LACERA counters that its employees are County
employees only insofar as they are subject to County civil service
rules and eligible to receive certain benefits of County
employment, like participating in the retirement system.
Notwithstanding the home rule provisions, LACERA urges that
Proposition 162 changed the legal landscape when it gave
retirement boards “plenary authority” over “administration of
the [retirement] system.” (Cal. Const., art. XVI, § 17.) It argues
this plenary authority over administration includes the power
to determine classification and compensation for its personnel.
LACERA further asserts that CERL imposes a ministerial duty
on the County to accept LACERA’s classification and salary
designations and include them in the County’s salary ordinance.
(See § 31522.1.)
Resolving these conflicts requires consideration of a
number of interconnected constitutional and statutory
provisions governing the powers of county retirement boards.
We first turn to the Constitution, then consider the related
statutory questions.
A. Constitutional Authority over Retirement System
Appointments
As noted, the California Constitution grants counties
control over employee hiring. The constitutional powers of
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counties are grounded in Article XI, which provides for “Local
Government.” Article XI divides the state into counties and
requires that the Legislature provide for county powers,
including the formation in each county of an elected governing
body, such as a board of supervisors. (Cal. Const., art. XI, § 1.)
In general law counties, the Constitution directs that the
governing body “shall provide for the number, compensation,
tenure, and appointment of employees.” (Id., subd. (b); see
§ 25300.) This “ ‘home rule’ ” provision was “specifically
intended to deprive the Legislature of the power to set
compensation for county employees and to entrust that
authority to county governing bodies.” (County of Sonoma v.
Superior Court (2009) 173 Cal.App.4th 322, 338 (County of
Sonoma); see Retired Employees Assn. of Orange County, Inc. v.
County of Orange (2011) 52 Cal.4th 1171, 1184 (Retired
Employees).) Similar provisions apply to counties that have
adopted a charter for their governance. (Cal. Const., art. XI,
§ 4.) In charter counties, such as Los Angeles County, the
governing body has constitutional authority over “fixing and
regulating . . . , by ordinance,” the number of “persons to be
employed” as well as their “powers, duties, qualifications, and
compensation.” (Cal. Const, art. XI, § 4, subd. (f).) “Under the
‘home rule’ doctrine, county charter provisions concerning the
operation of the county, and specifically including the county’s
right to provide ‘for the number, compensation, tenure, and
appointment of employees’ (that is, a county’s core operations)”
take precedence over conflicting state laws. (Holmgren, supra,
159 Cal.App.4th at p. 601; see Cal. Const., art. XI, § 4, subd. (g).)
As germane here, the County urges that the home rule doctrine
prevents statewide legislation from usurping county
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Opinion of the Court by Corrigan, J.
governments’ constitutional authority to set the salaries of their
employees.
Elsewhere in the Constitution, article XVI, section 17
regulates the investment of public pension or retirement funds.
The constitutional question here is whether Proposition 162’s
amendments to section 17 shifted authority over classification
and salary setting for retirement system staff away from county
governing bodies and to retirement boards. There is no dispute
that voters have the authority to amend the Constitution in this
way. The question is whether they intended to do so. To answer
that question, we must construe article XVI, section 17, as that
provision was amended by Proposition 162.
Familiar rules guide the analysis. “We apply the same
interpretive principles to initiatives as to legislative
enactments, beginning with the text as the best guide to voter
intent and turning to extrinsic sources such as ballot materials
when necessary to resolve ambiguities.” (In re C.B. (2018) 6
Cal.5th 118, 125 (C.B.).) For a provision enacted by the
electorate, “it is the voters’ intent that controls.” (People v. Park
(2013) 56 Cal.4th 782, 796.) “Once the electorate’s intent has
been ascertained, the provisions must be construed to conform
to that intent. [Citation.] ‘[W]e may not properly interpret the
measure in a way that the electorate did not contemplate: the
voters should get what they enacted, not more and not less.’ ”
(Ibid.)
1. Background Regarding Proposition 162’s Passage
Article XVI, section 17 “reached [its] current form through
two ballot initiatives. The first, Proposition 21, [was] passed in
1984 in an apparent response to the emerging financial markets
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Opinion of the Court by Corrigan, J.
of the 1980’s.” (O’Neal, supra, 8 Cal.App.5th at p. 1202.)
Motivated by concerns that market changes made retirement
benefits vulnerable to various risks, Proposition 21 amended
section 17 and “introduced the principle that ‘assets of a public
pension or retirement system are trust funds’ that ‘shall be held
for the exclusive purposes of providing benefits to participants
in the pension or retirement system and their beneficiaries and
defraying reasonable expenses of administering the system.’ ”
(O’Neal, at p. 1202.)
The second ballot initiative, Proposition 162, was passed
in 1992 in response to “actions by the Governor and Legislature
to balance the state budget by limiting or delaying the state’s
employer contributions to CalPERS.” (Westly, supra, 105
Cal.App.4th at p. 1100; see O’Neal, supra, 8 Cal.App.5th at
p. 1203.) Among these actions, 1982 legislation had barred the
state from making a portion of its employer contributions and
required instead that any deficiencies be covered by CalPERS
reserve funds. (Westly, at p. 1100; Claypool v. Wilson (1992) 4
Cal.App.4th 646, 655.) Then, in the early 1990’s, the Legislature
made several changes to delay the state’s employer contribution
payments. In 1990, it changed the payment schedule from
monthly to quarterly; the next year, it changed the schedule to
semiannually; and the year after that, it changed the schedule
to “ ‘ “semiannually, six months in arrears.” ’ ” (Westly, at
p. 1100; see Board of Administration v. Wilson (1997) 52
Cal.App.4th 1109, 1117.) In 1991, the Legislature also repealed
statutes granting cost-of-living adjustments to retirees and
passed legislation directing that these adjustment expenditures
be allocated instead to defray the state’s employer contributions.
(Claypool, at pp. 657–658.) The same 1991 law transferred
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Opinion of the Court by Corrigan, J.
many actuarial duties from the CalPERS retirement board to
the governor. (Id. at p. 658.)
It was in this environment that voters passed Proposition
162, the California Pension Protection Act of 1992, and
expanded the authority of public pension retirement boards. As
amended by Proposition 162, the opening paragraph of article
XVI, section 17 gives public pension retirement boards “plenary
authority and fiduciary responsibility for investment of moneys
and administration of the system.” (Ballot Pamp., Gen. Elec.
(Nov. 3, 1992) text of Prop. 162, § 4, p. 70, italics omitted
(hereafter Ballot Pamp.).) Voters further delineated that
responsibility in the subdivisions that follow. (Id., at pp. 70–71
[amending Cal. Const., art. XVI, § 17, subds. (a)–(h)].) Those
subdivisions provide that a retirement board has “sole and
exclusive fiduciary responsibility” over managing system assets
and assuring prompt delivery of benefits and services to
participants and their beneficiaries. (Cal. Const., art. XVI, § 17,
subd. (a).) They return “the sole and exclusive power to provide
for actuarial services” to retirement boards (id., subd. (e)) and
specify that a board’s duty to participants and their beneficiaries
takes “precedence over any other duty” (id., subd. (b)). Other
subdivisions address the selection and removal of retirement
board members (id., subd. (f)), define the term “ ‘retirement
board’ ” (id., subd. (h)), and provide that the Legislature “may
. . . continue to prohibit certain investments” when in the public
interest (id., subd. (g)). Finally, Proposition 162 left
substantively unchanged two subdivisions that require
retirement board members to act with prudence and diligence
(Cal. Const., art. XVI, § 17, subd. (c)) and to diversify
investments (id., subd. (d)). Taken together, section 17’s
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Opinion of the Court by Corrigan, J.
subdivisions shed light on the scope of the “plenary authority
and fiduciary responsibility” the voters intended to confer. (Cal.
Const., art. XVI, § 17.)7
7
The full text of article XVI, section 17, with language
added by Proposition 162 in italics, is as follows:
“Notwithstanding any other provisions of law or this
Constitution to the contrary, the retirement board of a public
pension or retirement system shall have plenary authority and
fiduciary responsibility for investment of moneys and
administration of the system, subject to all of the following:
“(a) The retirement board of a public pension or retirement
system shall have the sole and exclusive fiduc