County of Los Angeles v. Sasaki

In County of Los Angeles v. Sasaki (1994) 23 Cal. App. 4th 1442, the court reviewed the same legislation that is the basis of the claim for subvention in this appeal. The court traced the history of education funding from Serrano through the post-Proposition 13 legislation, noting that the Legislature's bailout of counties and distribution of the remaining tax revenues was upheld in Amador Valley Joint Union High Sch. Dist. v. State Bd. of Equalization (1978) ( Sasaki, supra, 23 Cal. App. 4th at pp. 1450-1452.) The Sasaki court recognized that in the wake of Proposition 13, the state assumed a larger share of the funding of schools, but found no intent to prevent the state from altering the proportionate shares of revenue to address future changed conditions. (Sasaki, supra, 23 Cal. App. 4th at p. 1456.) The fact that the state shifted revenue away from the schools and towards local government after Proposition 13 did not restrict the state's power to change the allocation again, "in the context of comprehensive legislative planning for the funding of both entities from a variety of sources, including property tax revenue." ( Sasaki, supra, 23 Cal. App. 4th at p. 1457.)