Eiskamp v. Pajaro Valley Water Management Agency
203 Cal. App. 4th 97
Cal. Ct. App.2012Background
- Agency enacted three ordinances increasing groundwater augmentation charges (2002-02, 2003-01, 2004-02) without complying with constitutional notice/consent procedures.
- Several lawsuits challenging the ordinances were filed, culminating in a 2008 stipulated judgment resolving the Consolidated and Amrhein actions and refunding charges from 2003-01 and 2004-02.
- In 2010, Eiskamp, a Board member and landowner within the Agency, filed suit seeking a declaration that Ordinance 2002-02 was void, refunds, and cessation of collection.
- Trial court sustained the Agency’s demurrer for lack of standing and res judicata, entering judgment for the Agency.
- Appellate court held Eiskamp had standing due to direct, substantial interest but affirmed rejection on res judicata grounds because the stipulated agreement resolved related claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Eiskamp have standing to seek writ relief? | Eiskamp asserts direct, substantial property interests subject to the charges. | Eiskamp, as a Board member, is not a beneficially interested party and lacks standing. | Eiskamp has standing due to direct, substantial property interests. |
| Is the action barred by res judicata due to the stipulated agreement resolving pending litigation? | Litigation predicates were not fully resolved; claims remain valid. | Stipulated agreement extinguished all claims arising from the Pending Litigation, including validity of augmentation charges. | Barred by res judicata; the stipulated agreement precludes relitigating these issues. |
Key Cases Cited
- Mycogen Corp. v. Monsanto Co., 487 U.S. 468 (Cal. 2002) (preclusion principles and final judgment on the merits)
- Friedland v. City of Long Beach, 62 Cal.App.4th 835 (Cal.App. 1998) (need for single dispositive judgment in validation actions)
- Carsten v. Psychology Examining Com., 27 Cal.3d 793 (Cal. 1980) (standing and beneficial interest; taxpayer standing limitations)
- Braude v. City of Los Angeles, 226 Cal.App.3d 83 (Cal.App. 1990) (public standing and loss of citizen-taxpayer status for council member)
- Bonander v. Town of Tiburon, 46 Cal.4th 646 (Cal. 2009) (broadstanding for interested persons in validation context)
- Save the Plastic Bag Coalition v. City of Manhattan Beach, 52 Cal.4th 155 (Cal. 2011) (standing where direct and substantial public interests implicated)