Enforcement of a Public Duty
Bozung v. Local Agency Formation Com. (1975) 13 Cal. 3d 263, 272 118 Cal. Rptr. 249, 529 P.2d 1017, found beneficial interests in the plaintiffs in that case but added: "Moreover, plaintiffs have standing 'to procure enforcement of a public duty, . . .' " (Citing Kappadahl v. Alcan Pacific Co. (1963) 222 Cal. App. 2d 626, 643 35 Cal. Rptr. 354.)
This cryptic comment refers to the matter of a citizen suit.
Specifically, where an issue is one of public right, and the object of the action is to procure the enforcement of a public duty, it is sufficient that the plaintiff be interested as a citizen in having the laws executed and the duty in question enforced. (Kappadahl, at p. 643; see Common Cause v. Board of Supervisors, supra, 49 Cal. 3d at p. 439; Green v. Obledo (1981) 29 Cal. 3d 126, 144 172 Cal. Rptr. 206, 624 P.2d 256.)
A plaintiff's beneficial interest and the interests of a citizen with respect to public duty are separate bases for establishing standing to pursue an action.
Waste Management also asserts standing pursuant to Public Resources Code section 21177, subdivision (b). to these bases we would add the right of a taxpayer to enjoin a waste of public funds or property (Code Civ. Proc., 526a), as an arguable basis for standing here.