Reclamation District v. Superior Court

In Reclamation District v. Superior Court (1916) 171 Cal. 672, the Supreme Court held "that a county (or reclamation or school district) is a mere political agency of the state, that it holds its property on behalf of the state for governmental purposes, and that it has no private proprietary interest in such property as against the state." (Id. at p. 680.) There, a state statute had created a reclamation district and required it to construct a levee in a specified location. (Id. at pp. 674-675.) Sutter County sued the reclamation district. It claimed that the levee would cause flooding which would damage or destroy the county courthouse, jail, and hall of records, and assorted county bridges and highways as well (Id. at p. 674) and hence that the statute would effect a taking of county property without compensation, in violation of due process. (Id. at p. 679.) The Supreme Court rejected this contention: "The public building, roads, and bridges of a county are not the private property of the county in such sense as to authorize the county to object to the taking or damaging thereof by the state for public purposes. The counties are governmental agencies of the state , and the property intrusted to their governmental management is public property. The proprietary interest in all such property belongs to the public, and, if there be a legal title in the county, it is a title held in trust for the whole public. In the absence of constitutional restrictions, the legislature has full control of the property held by the counties as agencies of the state, and may dispose of that property without the consent of the county or without compensating it. " (Reclamation District v. Superior Court, supra, 171 Cal. at p. 679.)