Chesebro v. Los Angeles County Flood Control District

Background

A property owner and the City of Los Angeles challenged a California law that lets the Los Angeles flood control district accept the drainage improvements of eleven smaller drainage districts. The law, added in 1937 to a 1915 flood-control statute, lets the board of supervisors accept “all, but not less than all” such works and makes the district liable for bonds on the transferred projects. The owner says the board will levy annual special assessments on all real estate in the flood-control district to pay those obligations without giving him a chance to be heard about whether his land is specially benefited.

Reasoning

The Court reviewed whether the State violated the Fourteenth Amendment by denying an opportunity to be heard on benefits. It held that where the legislature has itself found — expressly or by implication — that land in a district will be specially benefited, that finding is presumed to rest on adequate inquiry and is conclusive unless shown to be arbitrary or plainly without foundation. The Court relied on prior decisions allowing states to create local improvement districts and to tax lands that benefit from those works, and concluded the state court reasonably inferred the legislature made the necessary finding.

Real world impact

The ruling permits the flood-control district to accept the transferred drainage works and to levy the described assessments on all land in the district without individualized hearings about benefits, binding property owners unless they can show the legislative finding was arbitrary. The decision affirms the state court’s judgment and rejects the claim that federal due process required a separate hearing in this case.