City of Palmdale v. Board of Equalization, 141 Cal. Rptr. 3d 719

Parties moved to settle by vacating the trial court judgment and reinstating the Board’s decision; the court denied vacatur due to public interests.
Board allocates local sales tax revenues among cities and hears tax appeals; its decisions affect California’s fiscal condition and taxpayers.
Warehouse rule and pool system governed local allocation; Board amended regulations in 2006 to direct warehouse-based allocations in certain cases.
Pomona sought reallocation in 1994; Board initially denied; later, Board Management and Board held proceedings under evolving regulations.
In 2009–2010, Board granted Pomona’s petition in part; petitioners sought writ of mandate; trial court found procedural and legal deficiencies.
Trial court concluded potential retroactive application issues, due process concerns, laches, and AP A compliance problems; ordered reconsideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether vacatur would adversely affect the public interest	Public interests harmed by vacating judgment.	Vacatur would relieve financial impact on Board and settle costs.	Yes; public interests would be adversely affected, so vacatur denied.
Whether Board’s January 15, 2010 decision was properly reasoned as quasi-judicial	Board needed express findings and discussion of evidence.	Board’s decision did not require extended findings.	Board’s decision required formal findings; trial court correctly scrutinized it.
Whether retroactive application of 2006 amendments was authorized	Retroactive application lacked authority.	Board had clear authority to apply regulations retroactively.	board retroactive application questioned; trial court’s concern sustained.
Whether due process was violated by reallocating funds already received and spent	Cities had vested rights in funds; due process required notice.	Due process arguments did not address notice issues sufficiently.	Due process concerns noted; merits of reallocation scrutinized.
Whether laches barred Pomona’s appeal	Longstanding administrative process; delay justified by complex proceedings.	Eight-year delay was unreasonable and prejudicial.	Laches applied; Board to be constrained by finality considerations.

Neary v. Regents of the University of California, 3 Cal.4th 273 (Cal. 1992) (reversal presumptions for stipulated settlements altered by statute)
Hardisty v. Hinton & Alfert, 124 Cal.App.4th 999 (Cal. App. 2004) (presumption against stipulated reversals after 1999 amendment)
Topanga Ass’n, for a Scenic Community v. County of Los Angeles, 11 Cal.3d 506 (Cal. 1974) (requirement of reasoned administrative findings to aid review)