Background - In 2011 the Legislature dissolved most redevelopment agencies and created a statutory scheme (the Dissolution Law) to preserve redevelopment assets for taxing entities and to wind down redevelopment obligations. The law allowed cities/counties to elect to retain former redevelopment agencies' housing assets and functions or, if they did not, to have those housing functions transferred to a housing successor (often a local housing authority). - Section 34171 originally gave administrative cost allowances to successor agencies; in 2014 it was amended to create a limited "housing entity administrative cost allowance" payable to a local housing authority that assumed housing functions under section 34176(b)(2) or (3). - Section 34167.10 (added 2012) broadly defines "city" or "county" for purposes of the Dissolution Law to include entities that report to the city/county's CAFR, component units, or entities controlled by the city/county, and states that separate legal form is irrelevant for those purposes. - Several housing authorities (Montclair, Santa Rosa, Riverside, San Jacinto, Sonoma County housing authority) assumed housing successor roles and claimed the housing administrative cost allowance on their ROPS; the Department of Finance (DOF) denied those claims under §34167.10 because the housing authorities were reporting entities/component units or controlled by the sponsoring city/county. - Two trial courts split: Montclair granted a writ ordering payment to the housing authority (holding §34167.10 irrelevant), while Santa Rosa denied relief (holding §34167.10 bars allowance where the housing authority falls within its definition). The consolidated appeal presents whether housing authorities that meet §34167.10 criteria are eligible for the allowance. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---|---|---| | Whether housing authorities that assume housing functions but are reporting entities/component units or controlled by the sponsoring city/county are eligible for the §34171(p) housing entity administrative cost allowance | Housing authorities: they were compelled to assume functions and §34171(p) grants allowance to any "local housing authority" that assumed housing functions under §34176(b); §34167.10 should not defeat that specific grant | DOF: §34167.10’s broad "notwithstanding any other law" definition brings those housing authorities within the sponsoring city/county for Dissolution Law purposes, making them ineligible for the allowance because sponsoring cities/counties cannot receive it | Court: Affirmed DOF — §34167.10 is part of the statutory scheme and bars the allowance for housing authorities that are reporting entities, component units, or controlled by the sponsoring city/county. Montclair reversed; Santa Rosa affirmed | ### Key Cases Cited California Redevelopment Assn. v. Matosantos, 53 Cal.4th 231 (2011) (background on redevelopment agencies, tax increment financing, and legislative intent in dissolving RDAs) California Correctional Peace Officers' Assn. v. State of California, 181 Cal.App.4th 1454 (2010) (standard that statutory interpretation is reviewed de novo) County of Sonoma v. Cohen, 235 Cal.App.4th 42 (2015) (examples of interlocking local entities and post-dissolution disputes over RDA transactions) City of Grass Valley v. Cohen, 17 Cal.App.5th 567 (2017) (discussing due diligence reviews and audits under the Dissolution Law) * Delaney v. Superior Court, 50 Cal.3d 785 (1990) (legislative history is unnecessary when statutory language is clear)