citizenry challenge (California) · Go Syfert
← California issues

citizenry challenge in California

43 California opinions name it 5 courts 1971–2025 9 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.

Followed or applied (25)

CaseFollowedCited
Blair v. Pitchessgreen
cal · 1971 · cited in 32 California opinions naming this issue, 1977–2025
2 sentences

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

1632
Wirin v. Parkergreen
cal · 1957 · cited in 7 California opinions naming this issue, 1971–2025
2 sentences

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

47
Van Atta v. Scottgreen
cal · 1980 · cited in 5 California opinions naming this issue, 1982–2017
2 sentences

2017(See Blair , supra , 5 Cal.3d at p. 267 , 96 Cal.Rptr. 42 , 486 P.2d 1242 .) We have previously described this purpose as " 'enabl[ing] a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.' " ( Id. at pp. 267-268, 96 Cal.Rptr. 42 , 486 P.2d 1242 .) In light of this purpose, it is crucial that the statute provide a "broad basis of relief." ( Van Atta , supra , 27 Cal.3d at p. 450, 166 Cal.Rptr. 149 , 613 P.2d 210 .) Accordingly, we have always construed section 526a liberally-though not in a manne

2017(See Blair , supra , 5 Cal.3d at p. 267 , 96 Cal.Rptr. 42 , 486 P.2d 1242 .) We have previously described this purpose as " 'enabl[ing] a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.' " ( Id. at pp. 267-268, 96 Cal.Rptr. 42 , 486 P.2d 1242 .) In light of this purpose, it is crucial that the statute provide a "broad basis of relief." ( Van Atta , supra , 27 Cal.3d at p. 450, 166 Cal.Rptr. 149 , 613 P.2d 210 .) Accordingly, we have always construed section 526a liberally-though not in a manne

45
White v. Davisgreen
cal · 1975 · cited in 8 California opinions naming this issue, 1980–2017
2 sentences

2017(See Blair , supra , 5 Cal.3d at p. 267 , 96 Cal.Rptr. 42 , 486 P.2d 1242 .) We have previously described this purpose as " 'enabl[ing] a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.' " ( Id. at pp. 267-268, 96 Cal.Rptr. 42 , 486 P.2d 1242 .) In light of this purpose, it is crucial that the statute provide a "broad basis of relief." ( Van Atta , supra , 27 Cal.3d at p. 450, 166 Cal.Rptr. 149 , 613 P.2d 210 .) Accordingly, we have always construed section 526a liberally-though not in a manne

2017(See Blair , supra , 5 Cal.3d at p. 267 , 96 Cal.Rptr. 42 , 486 P.2d 1242 .) We have previously described this purpose as " 'enabl[ing] a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.' " ( Id. at pp. 267-268, 96 Cal.Rptr. 42 , 486 P.2d 1242 .) In light of this purpose, it is crucial that the statute provide a "broad basis of relief." ( Van Atta , supra , 27 Cal.3d at p. 450, 166 Cal.Rptr. 149 , 613 P.2d 210 .) Accordingly, we have always construed section 526a liberally-though not in a manne

38
Los Altos Property Owners Assn. v. Hutcheongreen
calctapp · 1977 · cited in 4 California opinions naming this issue, 1979–2017
2 sentences

2017(Los Altos Property Owners Assn. v. Hutcheon (1977) 69 Cal.App.3d 22, 26 (Hutcheon).) Section 526a permits “ ‘[a]n action to obtain a judgment, restraining and preventing any illegal expenditure of, waste of, or injury to, the estate, funds, or other property of a county, town, city or city and county of the state, . . . against any officer thereof, or any agent, or other person, acting in its behalf.’ ” A common law taxpayer suit is limited to the “grounds [of] fraud, collusion, ultra vires, or a failure to perform a duty specifically enjoined.” (Hutcheon, at p. 26.) “The primary purpose of [

1992Code of Civil Procedure section 526a provides in part: "An action to obtain a judgment, restraining and preventing any illegal expenditure of, waste of, or injury to, the estate, funds, or other property of a county, town, city or city and county of the state, may be maintained against any officer thereof, or any agent, or other person, acting in its behalf, either by a citizen resident therein, or by a corporation, who is assessed for and is liable to pay, or, within one year before the commencement of the action, has paid, a tax therein." As stated by the Supreme Court in Blair v. Pitchess (

34
Cal. Dui Lawyers Ass'n v. Cal. Dep't of Motor Vehiclesgreen
calctapp5d · 2018 · cited in 3 California opinions naming this issue, 2023–2025
2 sentences

2023That mechanism, moreover, remains available even where the injury is insufficient to satisfy general standing requirements under [Code of Civil Procedure] section 367.” (Weatherford v. City of San Rafael (2017) 2 Cal.5th 1241, 1249 .) As our Supreme Court has explained, the purpose of taxpayer standing is to enable “‘“a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.”’ [Citation.] In light of this purpose, it is crucial that the statute provide a ‘“broad basis of relief.”’ [Citation.] Accordin

2023That mechanism, moreover, remains available even where the injury is insufficient to satisfy general standing requirements under [Code of Civil Procedure] section 367.” (Weatherford v. City of San Rafael (2017) 2 Cal.5th 1241, 1249 .) As our Supreme Court has explained, the purpose of taxpayer standing is to enable “‘“a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.”’ [Citation.] In light of this purpose, it is crucial that the statute provide a ‘“broad basis of relief.”’ [Citation.] Accordin

33
Weatherford v. City of San Rafaelgreen
cal · 2017 · cited in 6 California opinions naming this issue, 2019–2025
2 sentences

2023That mechanism, moreover, remains available even where the injury is insufficient to satisfy general standing requirements under [Code of Civil Procedure] section 367.” (Weatherford v. City of San Rafael (2017) 2 Cal.5th 1241, 1249 .) As our Supreme Court has explained, the purpose of taxpayer standing is to enable “‘“a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.”’ [Citation.] In light of this purpose, it is crucial that the statute provide a ‘“broad basis of relief.”’ [Citation.] Accordin

2023That mechanism, moreover, remains available even where the injury is insufficient to satisfy general standing requirements under [Code of Civil Procedure] section 367.” (Weatherford v. City of San Rafael (2017) 2 Cal.5th 1241, 1249 .) As our Supreme Court has explained, the purpose of taxpayer standing is to enable “‘“a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.”’ [Citation.] In light of this purpose, it is crucial that the statute provide a ‘“broad basis of relief.”’ [Citation.] Accordin

16
Crowe v. Boylegreen
cal · 1920 · cited in 3 California opinions naming this issue, 2010–2025
2 sentences

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

13
Sundance v. Municipal Courtgreen
cal · 1986 · cited in 2 California opinions naming this issue, 1992–2025
2 sentences

2025That mechanism, moreover, remains available even where the injury is insufficient to satisfy general standing requirements under . . . section 367.’ [Citation.] . . . ‘In light of 7 The statute provides in part: “An action to obtain a judgment, restraining and preventing any illegal expenditure of, waste of, or injury to, the estate, funds, or other property of a local agency, may be maintained against any officer thereof, or any agent, or other person, acting in its behalf, either by a resident therein, or by a corporation, who is assessed for and is liable to pay, or, within one year before

1992Code of Civil Procedure section 526a provides in part: "An action to obtain a judgment, restraining and preventing any illegal expenditure of, waste of, or injury to, the estate, funds, or other property of a county, town, city or city and county of the state, may be maintained against any officer thereof, or any agent, or other person, acting in its behalf, either by a citizen resident therein, or by a corporation, who is assessed for and is liable to pay, or, within one year before the commencement of the action, has paid, a tax therein." As stated by the Supreme Court in Blair v. Pitchess (

12
Irwin v. City of Manhattan Beachgreen
cal · 1966 · cited in 2 California opinions naming this issue, 1972–2013
2 sentences

2013The primary purpose of that section is "to 'enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.' [Citation.]" (Blair v. Pitchess (1971) 5 Cal.3d 258, 267-268, & fn. 4 .) The section has been extended "to include actions brought by nonresident taxpayers (Irwin v. City of Manhattan Beach (1966) 65 Cal.2d 13 , 18-20 . . .)." (Id. at p. 268.) The Supreme Court has also " permitted taxpayers to sue on behalf of a city or county to recover funds illegally expended.

1972J., McComb, J., Peters, J., Mosk, J., Burke, J., and Sullivan, J., concurred. 1 This expansive interpretation of the taxpayer’s standing described in Code of Civil Procedure section 526a supports that section’s primary purpose to “ ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Blair v. Pitchess, supra, 5 Cal.3d at pp. 267-268, quoting from Comment, Taxpayers' Suits: A Survey and Summary (1960) 69 Yale L.J. 895 , 904.) 2 See also Irwin v. City of Manhattan Beach (1966) 65 Cal.2d

12
Osburn v. Stonegreen
cal · 1915 · cited in 2 California opinions naming this issue, 1990–2013
2 sentences

2013(Osburn v. Stone (1915) 170 Cal. 480 , 482 . . . .)" (Ibid.) 6 Pekin, attorney Serverian had not withdrawn as counsel pursuant to Code of Civil Procedure section 284.

1990(Osburn v. Stone (1915) 170 Cal. 480, 482 [ 150 P. 367 ].) *514 Here, Boatowners have alleged they are California residents and taxpayers.

12
Midpeninsula Citizens for Fair Housing v. Westwood Investorsgreen
calctapp · 1990 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(See, e.g., Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582 , 618 [acknowledging that the Private Attorney General’s Act has “broad standing rules”]; Thompson v. Spitzer (2023) 90 Cal.App.5th 436 , 453 [“As our Supreme Court has explained, the purpose of taxpayer standing is to enable ‘“‘a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement’”‘“]; In re L.Y.L. (2002) 101 Cal.App.4th 942, 948 [in a juvenile dependency proceedings California courts “liberally construe the issue of standing

11
In Re LYLgreen
calctapp · 2002 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(See, e.g., Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582 , 618 [acknowledging that the Private Attorney General’s Act has “broad standing rules”]; Thompson v. Spitzer (2023) 90 Cal.App.5th 436 , 453 [“As our Supreme Court has explained, the purpose of taxpayer standing is to enable ‘“‘a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement’”‘“]; In re L.Y.L. (2002) 101 Cal.App.4th 942, 948 [in a juvenile dependency proceedings California courts “liberally construe the issue of standing

11
Pacific Gas & Electric Co. v. Minnettegreen
calctapp · 1953 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(See, e.g., Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582 , 618 [acknowledging that the Private Attorney General’s Act has “broad standing rules”]; Thompson v. Spitzer (2023) 90 Cal.App.5th 436 , 453 [“As our Supreme Court has explained, the purpose of taxpayer standing is to enable ‘“‘a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement’”‘“]; In re L.Y.L. (2002) 101 Cal.App.4th 942, 948 [in a juvenile dependency proceedings California courts “liberally construe the issue of standing

11
Langford v. Superior Courtgreen
cal · 1987 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(See, e.g., Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582 , 618 [acknowledging that the Private Attorney General’s Act has “broad standing rules”]; Thompson v. Spitzer (2023) 90 Cal.App.5th 436 , 453 [“As our Supreme Court has explained, the purpose of taxpayer standing is to enable ‘“‘a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement’”‘“]; In re L.Y.L. (2002) 101 Cal.App.4th 942, 948 [in a juvenile dependency proceedings California courts “liberally construe the issue of standing

11
Save the Plastic Bag Coalition v. City of Manhattan Beachgreen
cal · 2011 · cited in 1 California opinions naming this issue, 2017–2017
11
CHIATELLO v. City and County of San Franciscogreen
calctapp · 2010 · cited in 1 California opinions naming this issue, 2015–2015
11
Cates v. California Gambling Control Commissiongreen
calctapp · 2007 · cited in 1 California opinions naming this issue, 2010–2010
11
Santa Barbara County Coalition Against Automobile Subsidies v. Santa Barbara County Assn. of Governmentsgreen
calctapp · 2008 · cited in 1 California opinions naming this issue, 2010–2010
11
People v. Parragreen
calctapp · 1973 · cited in 1 California opinions naming this issue, 1999–1999
11
State v. Alexandergreen
mdctspecapp · 1998 · cited in 1 California opinions naming this issue, 1999–1999
11
People v. Gomezgreen
calctapp · 1964 · cited in 1 California opinions naming this issue, 1999–1999
11
State v. Bridewellgreen
or · 1988 · cited in 1 California opinions naming this issue, 1999–1999
11
Arrieta v. Mahongreen
cal · 1982 · cited in 1 California opinions naming this issue, 1987–1987
11
Wehrle v. Board of Water & Power Commissionersgreen
cal · 1930 · cited in 1 California opinions naming this issue, 1972–1972
11

Distinguished, questioned or overruled (4)

CaseNegativeCited
Silver v. City of Los Angelesgreen
cal · 1961 · cited in 1 California opinions naming this issue, 1972–1972
11
Local No. 149, International Union United Automobile, Aircraft & Agricultural Implement Workers v. American Brake Shoe Co.green
scotus · 1962 · cited in 1 California opinions naming this issue, 1972–1972
11
Nelson v. Moore-McCormack Lines, Inc.green
scotus · 1962 · cited in 1 California opinions naming this issue, 1972–1972
11
Silver v. City of Los Angelesyellow
scotus · 1962 · cited in 1 California opinions naming this issue, 1972–1972
11

Also cited on this issue (23)

CaseCitedYears
Connerly v. State Personnel Board green
calctapp · 2001
2 sentences

2021No showing of special damage to a particular taxpayer is required as a requisite for bringing a taxpayer suit.” (Connerly v. State Personnel Bd. (2001) 92 Cal.App.4th 16, 29 .) The primary purpose of section 526a is to “ ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Blair v. Pitchess (1971) 5 Cal.3d 258 , 267–268 (Blair).) To promote this remedial purpose, section 526a is construed broadly.

2021No showing of special damage to a particular taxpayer is required as a requisite for bringing a taxpayer suit.” (Connerly v. State Personnel Bd. (2001) 92 Cal.App.4th 16, 29 .) The primary purpose of section 526a is to “ ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Blair v. Pitchess (1971) 5 Cal.3d 258 , 267–268 (Blair).) To promote this remedial purpose, section 526a is construed broadly.

42020–2021
Ahlgren v. Carr green
calctapp · 1962
2 sentences

1977In speaking of section 526a of the Code of Civil Procedure, 1 the Supreme Court stated *721 in Blair v. Pitchess, 5 Cal.3d 258 , at pages 267-268 [ 96 Cal.Rptr. 42 , 486 P.2d 1242 , 45 A.L.R.3d 1206 ]: “The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ (Comment, Taxpayers’ Suits: A Survey and Summary (1960) 69 Yale L.J. 895 , 904.)” In Ahlgren v. Carr, 209 Cal.App.2d 248 , at page 253 [ 25 Cal.Rptr. 887 ], the cour

1977In speaking of section 526a of the Code of Civil Procedure, 1 the Supreme Court stated *721 in Blair v. Pitchess, 5 Cal.3d 258 , at pages 267-268 [ 96 Cal.Rptr. 42 , 486 P.2d 1242 , 45 A.L.R.3d 1206 ]: “The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ (Comment, Taxpayers’ Suits: A Survey and Summary (1960) 69 Yale L.J. 895 , 904.)” In Ahlgren v. Carr, 209 Cal.App.2d 248 , at page 253 [ 25 Cal.Rptr. 887 ], the cour

31977–2025
California State Employees' Ass'n v. Williams green
calctapp · 1970
2 sentences

2025Indeed, it has been held that taxpayers may sue state officials to enjoin such officials from illegally expending state funds. ([ Ahlgren, supra,] 209 Cal.App.2d 248 , 252– 254 . . . ; [ Williams, supra,] 7 Cal.App.3d 390 , 395 . . . .)” (Blair, at p. 268, italics added.) To the extent the italicized passage has been understood as an authoritative interpretation of former section 526a, it is problematic dictum.

2025Indeed, it has been held that taxpayers may sue state officials to enjoin such officials from illegally expending state funds. ([ Ahlgren, supra,] 209 Cal.App.2d 248 , 252– 254 . . . ; [ Williams, supra,] 7 Cal.App.3d 390 , 395 . . . .)” (Blair, at p. 268, italics added.) To the extent the italicized passage has been understood as an authoritative interpretation of former section 526a, it is problematic dictum.

22025–2025
Mines v. Del Valle green
cal · 1927
2 sentences

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

2025The primary purpose of this statute, originally enacted in 1909, is to ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement.’ ” (Id. at pp. 267–268, fn. omitted, citing Comment, Taxpayers’ Suits: A Survey, supra, 69 Yale L.J. at p. 904.) Our analysis in Blair then relied on cases cited earlier in this opinion, including Parker, supra, 48 Cal.2d 890 , and Mines, supra, 201 Cal. 273 , to support the proposition that “California courts have consistently construed section 526a liberally to ach

22025–2025
People v. Ray green
cal · 1999
2 sentences

2018As a matter of common sense, it would be anomalous to deny a police officer charged with protecting the citizenry the privilege accorded every other individual who intercedes to aid another or protect another's property. ( Ibid . ) " 'A warrantless entry of a dwelling is constitutionally permissible where the officers' conduct is prompted by the motive of preserving life and reasonably appears to be necessary for that purpose. [Citations.]' " ( Ibid . ) Pursuant to the community caretaking exception, police officers are expected to check on the welfare of people who cannot care for themselves

2018As a matter of common sense, it would be anomalous to deny a police officer charged with protecting the citizenry the privilege accorded every other individual who intercedes to aid another or protect another's property. ( Ibid . ) " 'A warrantless entry of a dwelling is constitutionally permissible where the officers' conduct is prompted by the motive of preserving life and reasonably appears to be necessary for that purpose. [Citations.]' " ( Ibid . ) Pursuant to the community caretaking exception, police officers are expected to check on the welfare of people who cannot care for themselves

22018–2018
Animal Legal Defense Fund v. California Exposition & State Fairs green
calctapp · 2015
2 sentences

2016It provides “a general citizen remedy for controlling illegal government activity.” (White v. Davis (1975) 13 Cal.3d 757, 763 .) Its primary purpose is to “ ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the 9 Even the court in ALDF, supra, 239 Cal.App.4th 1286 , believed that Schur stood for no more than the proposition that a taxpayer action based on violation of a criminal statute is not proper where an administrative remedy is available.

2016It provides “a general citizen remedy for controlling illegal government activity.” (White v. Davis (1975) 13 Cal.3d 757, 763 .) Its primary purpose is to “ ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the 9 Even the court in ALDF, supra, 239 Cal.App.4th 1286 , believed that Schur stood for no more than the proposition that a taxpayer action based on violation of a criminal statute is not proper where an administrative remedy is available.

22016–2016
Torres v. City of Yorba Linda green
calctapp · 1993
2 sentences

2014A vehicle so impounded shall be impounded for 30 days.” 2 funds, or other property of a county, town, city or city and county of the state, may be maintained against any officer thereof, or any agent, or other person, acting in its behalf, either by a citizen resident therein . . . who is assessed for and is liable to pay, or, within one year before the commencement of the action, has paid, a tax therein.” (Italics added.) The fundamental purpose of this statute is to “ ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts be

2014A vehicle so impounded shall be impounded for 30 days.” 2 funds, or other property of a county, town, city or city and county of the state, may be maintained against any officer thereof, or any agent, or other person, acting in its behalf, either by a citizen resident therein . . . who is assessed for and is liable to pay, or, within one year before the commencement of the action, has paid, a tax therein.” (Italics added.) The fundamental purpose of this statute is to “ ‘enable a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts be

22014–2014
Simms v. NPCK Enterprises, Inc. green
calctapp · 2003
1 sentence

2025Taxpayer Standing “Taxpayer standing derives from . . . section 526a, subdivision (a).” Thompson v. Spitzer (2023) 90 Cal.App.5th 436 , 453.)7 “[S]ection 526a . . . authorizes actions by a resident taxpayer against officers of a county, town, city, or city and county to obtain an injunction restraining and preventing the illegal expenditure of public funds.” (Blair v. Pitchess (1971) 5 Cal.3d 258, 267 , superseded by statute on another ground as stated in Simms v. NPCK Enterprises, Inc. (2003) 109 Cal.App.4th 233, 242-243 .) “The ‘primary purpose’ of the statute ‘is to “enable a large body of

12025–2025
Grant v. McAuliffe green
cal · 1953
1 sentence

2024(See Donald v. Cafe Royale, Inc. (1990) 218 Cal.App.3d 168, 184 .) 15 California survivor laws provide that “a cause of action for or against a person is not lost by reason of the person’s death.” (§ 377.20.) “A cause of action that survives the death of the person entitled to commence an action . . . passes to the decedent’s successor in interest . . . .” (§ 377.30.) Under California law, a “successor in interest has standing to bring any causes of action that the decedent himself could have asserted.” (Estate of Sanchez v. County of Stanislaus (E.D.Cal., Nov. 14, 2023, No. 1:18CV-00977- ADA-

12024–2024
Estate of Lopez v. Gelhaus green
cand · 2016
1 sentence

2024(See Donald v. Cafe Royale, Inc. (1990) 218 Cal.App.3d 168, 184 .) 15 California survivor laws provide that “a cause of action for or against a person is not lost by reason of the person’s death.” (§ 377.20.) “A cause of action that survives the death of the person entitled to commence an action . . . passes to the decedent’s successor in interest . . . .” (§ 377.30.) Under California law, a “successor in interest has standing to bring any causes of action that the decedent himself could have asserted.” (Estate of Sanchez v. County of Stanislaus (E.D.Cal., Nov. 14, 2023, No. 1:18CV-00977- ADA-

12024–2024
Korean Philadelphia Presbyterian Church v. California Presbytery green
calctapp · 2000
1 sentence

2024(See, e.g., Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582 , 618 [acknowledging that the Private Attorney General’s Act has “broad standing rules”]; Thompson v. Spitzer (2023) 90 Cal.App.5th 436 , 453 [“As our Supreme Court has explained, the purpose of taxpayer standing is to enable ‘“‘a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement’”‘“]; In re L.Y.L. (2002) 101 Cal.App.4th 942, 948 [in a juvenile dependency proceedings California courts “liberally construe the issue of standing

12024–2024
Donald v. Cafe Royale, Inc. green
calctapp · 1990
1 sentence

2024(See Donald v. Cafe Royale, Inc. (1990) 218 Cal.App.3d 168, 184 .) 15 California survivor laws provide that “a cause of action for or against a person is not lost by reason of the person’s death.” (§ 377.20.) “A cause of action that survives the death of the person entitled to commence an action . . . passes to the decedent’s successor in interest . . . .” (§ 377.30.) Under California law, a “successor in interest has standing to bring any causes of action that the decedent himself could have asserted.” (Estate of Sanchez v. County of Stanislaus (E.D.Cal., Nov. 14, 2023, No. 1:18CV-00977- ADA-

12024–2024
Loma Portal Civic Club v. American Airlines, Inc. green
cal · 1964
1 sentence

2024(See, e.g., Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582 , 618 [acknowledging that the Private Attorney General’s Act has “broad standing rules”]; Thompson v. Spitzer (2023) 90 Cal.App.5th 436 , 453 [“As our Supreme Court has explained, the purpose of taxpayer standing is to enable ‘“‘a large body of the citizenry to challenge governmental action which would otherwise go unchallenged in the courts because of the standing requirement’”‘“]; In re L.Y.L. (2002) 101 Cal.App.4th 942, 948 [in a juvenile dependency proceedings California courts “liberally construe the issue of standing

12024–2024
County of Santa Clara v. Superior Court of Santa Clara County green
calctapp · 2009
1 sentence

2022No showing of special damage to a particular taxpayer is required as a requisite for bringing a taxpayer suit. [Citation.] Rather, taxpayer suits provide a general citizen remedy for controlling illegal governmental activity. [Citation.] [¶] Citizen suits may be brought without the necessity of showing a legal or special interest in the result where the issue is one of public right and the object is to procure the enforcement of a public duty. [Citation.] Citizen suits promote the policy of guaranteeing citizens the opportunity to ensure that governmental bodies do not impair or 13 defeat publ

12022–2022
Gilbane Building Co. v. Superior Court green
calctapp · 2014
1 sentence

2017(Los Altos Property Owners Assn. v. Hutcheon (1977) 69 Cal.App.3d 22, 26 (Hutcheon).) Section 526a permits “ ‘[a]n action to obtain a judgment, restraining and preventing any illegal expenditure of, waste of, or injury to, the estate, funds, or other property of a county, town, city or city and county of the state, . . . against any officer thereof, or any agent, or other person, acting in its behalf.’ ” A common law taxpayer suit is limited to the “grounds [of] fraud, collusion, ultra vires, or a failure to perform a duty specifically enjoined.” (Hutcheon, at p. 26.) “The primary purpose of [

12017–2017
Wirin v. Horrall green
calctapp · 1948
12016–2016
Cornblum v. Board of Supervisors green
calctapp · 1980
12016–2016
People v. Eubanks green
cal · 1996
12016–2016
People v. Hill green
cal · 1974
11999–1999
People v. Roberts green
cal · 1956
11999–1999
Trim, Inc. v. County of Monterey green
calctapp · 1978
11992–1992
City of Ceres v. City of Modesto green
calctapp · 1969
11992–1992
Harnett v. County of Sacramento green
cal · 1925
11992–1992

Statutes the citing opinions construe

CA § Cal. Civil Code § 3369 (5) CA § Cal. Evidence Code § 452 (4) CA § Cal. Government Code § 1090 (4) CA § Cal. Government Code § 1092 (4) CA § Cal. Penal Code § 597 (4) CA § Cal. Penal Code § 597t (4) CA § Cal. Civil Code § 51 (3) CA § Cal. Education Code § 17406 (3) CA § Cal. Government Code § 100 (3) CA § Cal. Government Code § 81000 (3) CA § Cal. Penal Code § 596.5 (3) CA § Cal. Penal Code § 597.1 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 43 (1971–2025) PA 13 (1988–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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