Canyon North Co. v. Conejo Valley Unified School Dist

In Canyon North Co. v. Conejo Valley Unified School Dist. (1993) 19 Cal.App.4th 243, plaintiff developers sought to improve parcels of real property in the City of Thousand Oaks and paid defendant district certain school facility fees under protest. Plaintiffs argued, among other things, that the fee of $ 1.50 per square foot of residential construction bore no reasonable relationship to their projects. The trial court found to the contrary and the Second District Court of Appeal affirmed, stating in relevant part: "The District's growth plan was explicitly stated to be 'an essential element in determining the need for those fees.' The growth plan contained the information necessary to impose the fee. It included: "(1) A housing forecast showing the number of new housing units expected to be constructed within the District; "(2) An enrollment forecast showing the number of new students expected to be added due to the new housing; and "(3) A facilities analysis showing the nature and cost of the new facilities required to educate the new students from new housing. "Recent case law makes it clear that a district-wide fee is proper. 'Plaintiffs fault the report for failing to include "site-specific" data showing a "close connection" between new development and the fees to be imposed.... The fee at issue here is a general one applied to all new residential development and valid if supported by a reasonable relationship between the amount of the fee and estimated cost of services. Site-specific review is neither available nor needed. (Shapell Industries, Inc. v. Governing Board (1991) 1 Cal.App.4th 218, 239.)' ( Garrick Development Co. v. Hayward Unified School Dist., supra, 3 Cal.App.4th 320, 333-334, )" Canyon North Co. v. Conejo Valley Unified School Dist., supra, 19 Cal.App.4th at p. 251.)