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6 California opinions name it 1 courts 1977–2025 3 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Dean v. Kuchelgreen2 sentences1996(City of Los Angeles v. Offner (1942) 19 Cal.2d 483, 486 [ 122 P.2d 14 , 145 A.L.R. 1358 ], quoted in Dean v. Kuchel (1950) 35 Cal.2d 444, 446 [ 218 P.2d 521 ].) Our task is to determine whether the financing arrangement here falls within the Offner-Dean rule. 1 We are satisfied it does. 1996(City of Los Angeles v. Offner (1942) 19 Cal.2d 483, 486 [ 122 P.2d 14 , 145 A.L.R. 1358 ], quoted in Dean v. Kuchel (1950) 35 Cal.2d 444, 446 [ 218 P.2d 521 ].) Our task is to determine whether the financing arrangement here falls within the Offner-Dean rule. 1 We are satisfied it does. | 1 | 1 |
City of Los Angeles v. Offnergreen2 sentences1996(City of Los Angeles v. Offner (1942) 19 Cal.2d 483, 486 [ 122 P.2d 14 , 145 A.L.R. 1358 ], quoted in Dean v. Kuchel (1950) 35 Cal.2d 444, 446 [ 218 P.2d 521 ].) Our task is to determine whether the financing arrangement here falls within the Offner-Dean rule. 1 We are satisfied it does. 1996(City of Los Angeles v. Offner (1942) 19 Cal.2d 483, 486 [ 122 P.2d 14 , 145 A.L.R. 1358 ], quoted in Dean v. Kuchel (1950) 35 Cal.2d 444, 446 [ 218 P.2d 521 ].) Our task is to determine whether the financing arrangement here falls within the Offner-Dean rule. 1 We are satisfied it does. | 1 | 1 |
McBean v. City of Fresnogreen2 sentences1977The constitutional debt limitation provision was enacted “to prevent the improvident creation of inordinate debts which might be charged against taxpayers in ever increasing volume from year *174 to year.” (Lagiss v. County of Contra Costa, supra, 223 Cal.App.2d 77, 85 ; cf. McBean v. City of Fresno (1896) 112 Cal. 159, 164 [ 44 P. 358 ].) “Each year’s income and revenue must pay each year’s indebtedness and liability, and no indebtedness or liability incurred in one year shall be paid out of the income or revenue of any future year.” (McBean, supra, at p. 164 .) The constitutional provision i 1977The constitutional debt limitation provision was enacted “to prevent the improvident creation of inordinate debts which might be charged against taxpayers in ever increasing volume from year *174 to year.” (Lagiss v. County of Contra Costa, supra, 223 Cal.App.2d 77, 85 ; cf. McBean v. City of Fresno (1896) 112 Cal. 159, 164 [ 44 P. 358 ].) “Each year’s income and revenue must pay each year’s indebtedness and liability, and no indebtedness or liability incurred in one year shall be paid out of the income or revenue of any future year.” (McBean, supra, at p. 164 .) The constitutional provision i | 1 | 1 |
County of Sacramento v. Assessment Appeals Board No. 2green2 sentences1977The constitutional debt limitation provision was enacted “to prevent the improvident creation of inordinate debts which might be charged against taxpayers in ever increasing volume from year *174 to year.” (Lagiss v. County of Contra Costa, supra, 223 Cal.App.2d 77, 85 ; cf. McBean v. City of Fresno (1896) 112 Cal. 159, 164 [ 44 P. 358 ].) “Each year’s income and revenue must pay each year’s indebtedness and liability, and no indebtedness or liability incurred in one year shall be paid out of the income or revenue of any future year.” (McBean, supra, at p. 164 .) The constitutional provision i 1977The constitutional debt limitation provision was enacted “to prevent the improvident creation of inordinate debts which might be charged against taxpayers in ever increasing volume from year *174 to year.” (Lagiss v. County of Contra Costa, supra, 223 Cal.App.2d 77, 85 ; cf. McBean v. City of Fresno (1896) 112 Cal. 159, 164 [ 44 P. 358 ].) “Each year’s income and revenue must pay each year’s indebtedness and liability, and no indebtedness or liability incurred in one year shall be paid out of the income or revenue of any future year.” (McBean, supra, at p. 164 .) The constitutional provision i | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Starr v. City and County of San Francisco
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2 sentences2025(Ibid.) 8 Starr upheld the project lease, concluding that the lease was “in substantial compliance with the Offner-Dean rule.” (Starr, supra, 72 Cal.App.3d at p. 172 .) But the court concluded the repayment contract was invalid because it was not supported by consideration since the contract did not designate the city’s payments to the HUD as “ ‘rentals’ ” exchanged for use and occupancy of the premises. 2025(Ibid.) 8 Starr upheld the project lease, concluding that the lease was “in substantial compliance with the Offner-Dean rule.” (Starr, supra, 72 Cal.App.3d at p. 172 .) But the court concluded the repayment contract was invalid because it was not supported by consideration since the contract did not designate the city’s payments to the HUD as “ ‘rentals’ ” exchanged for use and occupancy of the premises. | 5 | 1996–2025 |
Rider v. City of San Diego
green
2 sentences2025(Dean, at p. 448.) In Rider, supra, 18 Cal.4th 1035 , the court revisited the Offner-Dean rule. 2025(Dean, at p. 448.) In Rider, supra, 18 Cal.4th 1035 , the court revisited the Offner-Dean rule. | 3 | 2025–2025 |
Taxpayers for Improving Public Safety v. Schwarzenegger
green
2 sentences2025One exception is “when a local government enters into a contingent obligation.” (Rider, supra, 18 Cal.4th at p. 1047 .) “ ‘A sum payable upon a contingency is not a debt, nor does it become a debt until the contingency happens.’ [Citation.] This contingency exception has been applied to uphold multiyear contracts, such as leases, where the governmental entity agrees to pay sums in succeeding periods in exchange for property, goods, or services to be provided during those periods. [Citation.] 5 Each periodic payment is viewed as a contemporaneous payment for the property, goods, or services rec 2025One exception is “when a local government enters into a contingent obligation.” (Rider, supra, 18 Cal.4th at p. 1047 .) “ ‘A sum payable upon a contingency is not a debt, nor does it become a debt until the contingency happens.’ [Citation.] This contingency exception has been applied to uphold multiyear contracts, such as leases, where the governmental entity agrees to pay sums in succeeding periods in exchange for property, goods, or services to be provided during those periods. [Citation.] 5 Each periodic payment is viewed as a contemporaneous payment for the property, goods, or services rec | 2 | 2025–2025 |
City of San Diego v. Rider
green
2 sentences2015(City of San Diego, supra, 47 Cal.App.4th at p. 1478 .) Rider argued that under Starr v. City and County of San Francisco (1977) 72 Cal.App.3d 164 [ 140 Cal.Rptr. 73 ] (Starr), it was improper “to spend part of the bond proceeds on off-site improvements to build a training facility and offices for the San Diego Chargers.” (City of San Diego, at p. 1492.) We rejected the argument, explaining: “In Starr , the court determined a municipal lease-back arrangement was valid because each rental payment would be supported by consideration furnished that year, i.e., occupancy and use of the project. [C 2015(City of San Diego, supra, 47 Cal.App.4th at p. 1478 .) Rider argued that under Starr v. City and County of San Francisco (1977) 72 Cal.App.3d 164 [ 140 Cal.Rptr. 73 ] (Starr), it was improper “to spend part of the bond proceeds on off-site improvements to build a training facility and offices for the San Diego Chargers.” (City of San Diego, at p. 1492.) We rejected the argument, explaining: “In Starr , the court determined a municipal lease-back arrangement was valid because each rental payment would be supported by consideration furnished that year, i.e., occupancy and use of the project. [C | 1 | 2015–2015 |
Rider v. County of San Diego
green
2 sentences1996We reject appellants’ alternative contention that the Supreme Court’s recent opinion in Rider v. County of San Diego (1991) 1 Cal.4th 1 [ 2 Cal.Rptr.2d 490 , 820 P.2d 1000 ] should be interpreted as a signal that our high court has adopted a new and less friendly attitude toward Offner-Dean. 1996We reject appellants’ alternative contention that the Supreme Court’s recent opinion in Rider v. County of San Diego (1991) 1 Cal.4th 1 [ 2 Cal.Rptr.2d 490 , 820 P.2d 1000 ] should be interpreted as a signal that our high court has adopted a new and less friendly attitude toward Offner-Dean. | 1 | 1996–1996 |
County of Los Angeles v. Byram
green
2 sentences1996Rejecting a similar argument, the Supreme Court upheld a lease between the county and its retirement board in County of Los Angeles v. Byram, supra, 36 Cal.2d 694 . [25] Rider's theory of "purposeful circumvention" simply has no application to this case. 1996Rejecting a similar argument, the Supreme Court upheld a lease between the county and its retirement board in County of Los Angeles v. Byram, supra, 36 Cal.2d 694 . [25] Rider's theory of "purposeful circumvention" simply has no application to this case. | 1 | 1996–1996 |
Lagiss v. County of Contra Costa
green
2 sentences1977(See, e.g., City of Montclair v. Donaldson (1962) 205 Cal.App.2d 201 [ 22 Cal.Rptr. 842 ]; McClain v. County of Alameda (1962) 209 Cal.App.2d 73 [ 25 Cal.Rptr. 660 ]; Lagiss v. County of Contra Costa (1963) 223 Cal.App.2d 77 [ 35 Cal.Rptr. 450 ].) Turning to the project lease and repayment contract here at issue, it initially appears that the lease by itself is in substantial compliance with the Offner-Dean rule: The base rental is for specified amounts to be paid by the City to the Agency “as rental for use and occupancy of the Project,” with rent abatement provisions if the project is not su 1977(See, e.g., City of Montclair v. Donaldson (1962) 205 Cal.App.2d 201 [ 22 Cal.Rptr. 842 ]; McClain v. County of Alameda (1962) 209 Cal.App.2d 73 [ 25 Cal.Rptr. 660 ]; Lagiss v. County of Contra Costa (1963) 223 Cal.App.2d 77 [ 35 Cal.Rptr. 450 ].) Turning to the project lease and repayment contract here at issue, it initially appears that the lease by itself is in substantial compliance with the Offner-Dean rule: The base rental is for specified amounts to be paid by the City to the Agency “as rental for use and occupancy of the Project,” with rent abatement provisions if the project is not su | 1 | 1977–1977 |
City of Montclair v. Donaldson
green
2 sentences1977(See, e.g., City of Montclair v. Donaldson (1962) 205 Cal.App.2d 201 [ 22 Cal.Rptr. 842 ]; McClain v. County of Alameda (1962) 209 Cal.App.2d 73 [ 25 Cal.Rptr. 660 ]; Lagiss v. County of Contra Costa (1963) 223 Cal.App.2d 77 [ 35 Cal.Rptr. 450 ].) Turning to the project lease and repayment contract here at issue, it initially appears that the lease by itself is in substantial compliance with the Offner-Dean rule: The base rental is for specified amounts to be paid by the City to the Agency “as rental for use and occupancy of the Project,” with rent abatement provisions if the project is not su 1977(See, e.g., City of Montclair v. Donaldson (1962) 205 Cal.App.2d 201 [ 22 Cal.Rptr. 842 ]; McClain v. County of Alameda (1962) 209 Cal.App.2d 73 [ 25 Cal.Rptr. 660 ]; Lagiss v. County of Contra Costa (1963) 223 Cal.App.2d 77 [ 35 Cal.Rptr. 450 ].) Turning to the project lease and repayment contract here at issue, it initially appears that the lease by itself is in substantial compliance with the Offner-Dean rule: The base rental is for specified amounts to be paid by the City to the Agency “as rental for use and occupancy of the Project,” with rent abatement provisions if the project is not su | 1 | 1977–1977 |
McClain v. County of Alameda
green
2 sentences1977(See, e.g., City of Montclair v. Donaldson (1962) 205 Cal.App.2d 201 [ 22 Cal.Rptr. 842 ]; McClain v. County of Alameda (1962) 209 Cal.App.2d 73 [ 25 Cal.Rptr. 660 ]; Lagiss v. County of Contra Costa (1963) 223 Cal.App.2d 77 [ 35 Cal.Rptr. 450 ].) Turning to the project lease and repayment contract here at issue, it initially appears that the lease by itself is in substantial compliance with the Offner-Dean rule: The base rental is for specified amounts to be paid by the City to the Agency “as rental for use and occupancy of the Project,” with rent abatement provisions if the project is not su 1977(See, e.g., City of Montclair v. Donaldson (1962) 205 Cal.App.2d 201 [ 22 Cal.Rptr. 842 ]; McClain v. County of Alameda (1962) 209 Cal.App.2d 73 [ 25 Cal.Rptr. 660 ]; Lagiss v. County of Contra Costa (1963) 223 Cal.App.2d 77 [ 35 Cal.Rptr. 450 ].) Turning to the project lease and repayment contract here at issue, it initially appears that the lease by itself is in substantial compliance with the Offner-Dean rule: The base rental is for specified amounts to be paid by the City to the Agency “as rental for use and occupancy of the Project,” with rent abatement provisions if the project is not su | 1 | 1977–1977 |