In County of Los Angeles v. Commission on State Mandates (1995) 32 Cal.App.4th 805, the court considered a Penal Code statute imposing duties on local governments and providing for state mandate reimbursement to local governments for implementing the duties. (County of Los Angeles, supra, 32 Cal.App.4th at pp. 811-812.) When the state discontinued payments, the county filed a test claim, asserting that the Legislature's provision granting state mandate reimbursement was a "final and unchallengeable determination that the statute constituted a state mandate." (Id. at p. 818.) The County of Los Angeles court disagreed. It held that "the Commission, as a quasi-judicial body, has the sole and exclusive authority to adjudicate whether a state mandate exists. Thus, any legislative findings are irrelevant to the issue of whether a state mandate exists, and the Commission properly determined that no state mandate existed." (Id. at p. 819.) In County of Los Angeles v. Commission on State Mandates, the Court of Appeal rejected the claim that Penal Code section 987.9, which required counties to provide indigent criminal defendants with certain defense funds, imposed an unfunded state mandate. ( County of Los Angeles, supra, at p. 814.) Los Angeles County filed the test claim after the State, which had enacted appropriations between 1977 and 1990 to reimburse counties for their costs under that statute, made no appropriation for the 1990-1991 fiscal year. ( Id. at pp. 812-813.) In rejecting the claim, the Court of Appeal held there was no state mandate because (among other things) Penal Code section 987.9 merely implemented the mandates of federal law. ( County of Los Angeles, supra, at p. 815.) The court explained that "even in the absence of Penal Code section 987.9, appellant and other counties would be responsible for providing ancillary services under the constitutional guarantees of due process under the Fourteenth Amendment and the Sixth Amendment right to counsel." ( County of Los Angeles, supra, at pp. 814-816.) In the County of Los Angeles case, the requirements of the test claim statute, Penal Code section 987.9, did not constitute a state mandate for purposes of section 6 because those requirements implemented the mandates of federal law.