## Facts

- The Regents of the University of California (UC) are constitutionally established as a public trust with “full powers of organization and government,” subject only to limited legislative control (fund security, endowment compliance, and specified competitive bidding procedures).
- Education Code § 92611 required the Regents to determine local “general prevailing” wages and to set minimum pay for certain hourly or per diem UC laborers, workmen, and mechanics at or above those rates.
- Labor organizations alleged the Regents were not complying with § 92611’s prevailing-wage mandate for covered UC employees.
- The labor organizations filed a petition for writ of mandate seeking to compel compliance.
- The trial court sustained the Regents’ demurrer without leave to amend and dismissed the petition on the ground that § 92611 conflicted with the Regents’ constitutional autonomy.
- The labor organizations appealed.

## Issues

1. Whether Education Code § 92611’s requirement that the Regents pay certain UC employees at least the local prevailing wage is unconstitutional as applied to UC because it infringes the Regents’ autonomy under article IX, section 9 of the California Constitution.
2. Whether the statute fits within the limited categories of legislative control permitted over UC (fund security, endowment compliance, or specified competitive bidding procedures).

## Decision

- The California Supreme Court affirmed the dismissal after demurrer was sustained without leave to amend.
- The court held Education Code § 92611 unconstitutional as applied to the Regents because it intruded on matters of internal UC governance reserved to the Regents by article IX, section 9.
- The court rejected arguments that the prevailing-wage mandate could be justified as legislation concerning fund security, endowment compliance, or competitive bidding.

## Legal Principles

- Article IX, section 9 grants the Regents broad, constitutionally based authority to organize and govern UC and sharply limits legislative power to regulate UC’s internal affairs.
- Legislative control over UC is permissible only where the Constitution authorizes it, including measures necessary to ensure security of UC funds, compliance with endowment terms, and certain competitive bidding procedures.
- Fixing compensation for UC employees is a core function of internal organization and government committed to the Regents, and legislation dictating substantive wage levels for UC employees improperly restricts Regents’ discretion.
- A statute that targets UC’s internal employment terms, rather than operating as neutral, generally applicable regulation or falling within an express constitutional exception, conflicts with UC’s constitutional autonomy.

## Conclusion

The court held that a statute compelling the Regents to set minimum wages for UC employees at prevailing local rates impermissibly regulates UC’s internal governance and exceeds the Legislature’s constitutionally limited authority over the University of California.


San Francisco Labor Council v. Regents of the Univ. of Cal., 26 Cal. 3d 785, 608 P.2d 277 (Cal. 1980)