## Facts

- Residents of the unincorporated community of Citrus Heights in Sacramento County sought to incorporate as a city.
- A 1986 petition obtained sufficient valid signatures to require the Local Agency Formation Commission of Sacramento County (LAFCO) to process an incorporation proposal.
- Sacramento County opposed aspects of the proposal, asserting incorporation would reduce county revenues and impair county services.
- During the proceedings, LAFCO modified proposed boundaries by excluding major sales-tax-generating shopping centers to mitigate fiscal harm to the county.
- On reconsideration, LAFCO excluded an additional shopping center and conditioned incorporation on a phased-in transfer of certain property-tax revenues to reduce revenue loss.
- LAFCO ordered a confirming incorporation election under Government Code § 57103, restricting voting to voters residing within the territory proposed for incorporation.
- The county and aligned plaintiffs claimed county residents outside the proposed city would be adversely affected but were excluded from voting.

## Issues

1. Whether Government Code § 57103 is unconstitutional on its face under equal protection by limiting incorporation-election voting to residents of the territory to be incorporated.
2. Whether § 57103 is unconstitutional as applied to the Citrus Heights incorporation given asserted fiscal and service impacts on county residents outside the proposed city.

## Decision

- The California Supreme Court held § 57103 constitutional both facially and as applied to the Citrus Heights incorporation.
- The Court reversed the Court of Appeal’s ruling that the statute was unconstitutional as applied.
- The Court applied rational-basis review, concluding the voting limitation was rationally related to legitimate state objectives within a comprehensive scheme regulating local government organization and boundary changes.

## Legal Principles

- A state has broad authority to create, modify, and reorganize political subdivisions and to prescribe procedures for local boundary changes, including incorporation.
- Limiting the franchise in an incorporation election to residents of the area proposed for incorporation does not, by itself, trigger strict scrutiny when it defines the relevant electorate rather than denying equal voting rights to residents within the affected electoral unit.
- Under equal protection, a voting limitation tied to territorial residency in a local-government-formation process is reviewed for a rational relationship to legitimate governmental purposes unless it significantly burdens a fundamental right or targets a suspect class.
- Legitimate purposes supporting such a limitation include ensuring those most directly governed by the new municipality decide incorporation and maintaining an orderly, workable system for boundary changes.
- Fiscal and service effects on surrounding residents do not necessarily require extending the franchise when statutory mechanisms exist to address intergovernmental impacts (e.g., boundary adjustments and revenue-allocation conditions) and the remaining impact is not shown to be constitutionally determinative.

## Conclusion

The court upheld Government Code § 57103’s restriction of incorporation-election voting to residents within the proposed city boundaries, finding the classification rationally related to legitimate objectives in the state’s local-government-formation framework and not violative of equal protection on its face or as applied to Citrus Heights.


Bd. of Supervisors of Sacramento Cnty. v. Local Agency Formation Comm’n, 3 Cal. 4th 903 (Cal. 1992)