Judge: Mary H. Strobel, Case: 22STCP01617, Date: 2022-08-23 Tentative Ruling

Case Number: 22STCP01617    Hearing Date: August 23, 2022    Dept: 82

Equitas Academy Charter School, Inc.,

 

v.

 

Los Angeles Unified School District, et al.,

 

Judge Mary Strobel

Hearing: August 23, 2022

 

 

Tentative Decision on Petition for Writ of Mandate 

 

 

Case No. 22STCP01617

 

 

           

Petitioner Equitas Academy Charter School, Inc. (“Petitioner”) petitions for a writ of ordinary mandate directing Respondents Los Angeles Unified School District (“LAUSD” or “District”), Board of Education of LAUSD (“Board”), and Superintendent Albert Carvalho (collectively “Respondents”) to receive Petitioner’s petition for the establishment of a charter school, as submitted to the District on March 30, 2022, in accordance with Education Code section 47605(b) and commence the statutory timelines for Board to hold a hearing on the petition and either grant or deny the charter. 

 

Judicial Notice

 

Respondents’ Request for Judicial Notice (“RJN”) Exhibit A – Granted.  (Evid. Code § 452(c); Pacific Gas & Electric Co. v. Superior Court (2017) 10 Cal.App.5th 563, 578, fn. 13 [taking judicial notice of a Senate committee report].) 

 

Petitioner’s objections to the RJN are overruled.  Petitioner’s objections go to the weight to be given the Senate Committee report in a statutory analysis of section 47605(b), not the propriety of judicial notice. 

 

Respondents’ Evidentiary Objections to Declaration of Margaret Ford

 

(1)      – (10) Overruled. 

 

Respondents’ Evidentiary Objections to Reply Declaration of Kevin Davis

 

(1)-(15) Sustained. 

 

Background and Procedural History

 

Education Code Section 47605(b)

 

            This petition concerns the statutory process by which the governing board of a school district “receives” and acts upon a petition for establishment of a charter school within the school district.  The central statutory provision is found in Education Code section 47605(b), which provides in pertinent part:

 

(b) No later than 60 days after receiving a petition, in accordance with subdivision (a), the governing board of the school district shall hold a public hearing on the provisions of the charter, at which time the governing board of the school district shall consider the level of support for the petition by teachers employed by the school district, other employees of the school district, and parents. Following review of the petition and the public hearing, the governing board of the school district shall either grant or deny the charter within 90 days of receipt of the petition, provided, however, that the date may be extended by an additional 30 days if both parties agree to the extension. A petition is deemed received by the governing board of the school district for purposes of commencing the timelines described in this subdivision on the day the petitioner submits a petition to the district office, along with a signed certification that the petitioner deems the petition to be complete.  (bold italics added.)

 

“[S]ection 47605 establishes a comprehensive process for approval of charter petitions, spelling out precisely what is expected of a charter applicant.”  (United Teachers of Los Angeles v. Los Angeles Unified School Dist. (2012) 54 Cal.4th 504, 526.)   

 

LAUSD Refuses to “Receive” Petitioner’s Charter School Petition

 

Petitioner is a nonprofit public benefit corporation that operates the Equitas Academy Charter Schools, a group of six public charter schools located in Los Angeles and authorized by LAUSD in accordance with Education Code section 47605.  (Ford Decl. ¶ 2.)  Petitioner planned to open Equitas Academy 7 (“EQ7”) as its seventh school in time for the 2022-2023 school year.  Petitioner’s charter petition for EQ7 is the subject of this action.  (Id. ¶ 5.)

 

            Petitioner met with LAUSD staff on March 30, 2022, at an intake appointment, and submitted its petition to establish EQ7 as a charter school within LAUSD (“EQ7 Petition” or “petition”).  Petitioner submitted a signed certification of completeness stating that Petitioner deemed the petition to be complete.  Petitioner also submitted thousands of pages of additional documentation in support of the petition.  (Ford Decl. ¶ 4; see AR 324 [certificate of completeness]; AR 146-12329 [entire petition].)  Petitioner utilized a LAUSD-required template for the certificate of completeness.  (Ford Decl. ¶ 4.)

 

LAUSD staff conducted the March 30 intake appointment via Zoom.  Over several hours, LAUSD staff assessed the completeness or sufficiency of the EQ7 Petition.  Ultimately, LAUSD staff notified Petitioner (via Zoom) that, in staff’s opinion, a portion of the submittal supporting the EQ7 Petition was incomplete.  Therefore, LAUSD staff informed Petitioner that the EQ7 Petition was not “received” by LAUSD or the Board. (Ford Decl. ¶¶ 4-5; Aguilar Decl. ¶¶ 9-15.) 

 

After the March 30 intake appointment concluded, LAUSD staff sent Petitioner a copy of its “2021-2022 New Independent Charter School Petition Application Intake Checklist” (the “Checklist”) concerning the EQ7 Petition.  The Checklist states that the EQ7 Petition was deemed an “Incomplete petition – not accepted for review.” (Ford Decl. ¶ 6; AR 10.)

 

Luis Aguilar, a LAUSD specialist in the LAUSD Charter School Division (“CSD”), was assigned to the team that reviewed the EQ7 Petition.  (Aguilar Decl. ¶ 15.)  The Checklist states that Aguilar conducted the “intake” for the EQ7 Petition.  (AR 10.)  In a declaration, Aguilar describes LAUSD’s determination that the petition was incomplete, as follows: [T]he EQ7 Petition submission did not completely address the requirement to include evidence of community engagement with all required stakeholder groups. Therefore, pursuant to the District’s Charter School Policies, the EQ7 Petition did not include all required components for a complete charter petition submission to the District, thus the statutory timelines described in Education Code section 47605, subdivision (b) did not commence on March 30, 2022.”  (Aguilar Decl. ¶ 15.)

 

In his declaration, Aguilar also describes the LAUSD policies and procedures that apply to LAUSD’s review of charter school petitions.  He further summarizes certain communications between Petitioner and LAUSD staff, starting March 15, 2022, related to Petitioner’s EQ7 Petition.  Where relevant, this evidence is discussed in the Analysis section below.  (Aguilar Decl. ¶¶ 1-9.)

 

LAUSD Confirms Refusal to Receive EQ7 Petition in Legal Correspondence

 

            On April 4, 2022, through counsel, Petitioner requested that LAUSD reconsider its position and confirm that the EQ7 Petition was “received” and will be acted upon by the District Board pursuant to Education Code section 47605(b). (AR 13.) 

 

On April 8, 2022, LAUSD’s General Counsel, Devora Navera Reed, responded to Petitioner and reiterated LAUSD’s position that the EQ7 Petition was “not considered received for purposes of starting the statutory timelines outlined in Education Code section 47605(b).” (AR 15.)  Reed explained LAUSD’s legal position as follows:

 

Contrary to the assertions made in the Equitas Letter, the Policy intake appointment requirements adopted by the LAUSD Board of Education are consistent with all applicable legal requirements including the Charter Schools Act (Ed. Code § 47600 et seq.) and made pursuant to the District’s discretionary control over the adoption and implementation of the policies and procedures governing charter schools.

 

The Policy enshrined specific intake requirements, among other things and as referenced below, for all LAUSD authorized and prospective charter schools to ensure that LAUSD consistently, effectively and meaningfully considered and processed each petition application accordingly.

 

(AR 14-15.)

 

            Reed quoted an LAUSD policy, which states in pertinent part: “At the intake appointment, CSD staff will determine if the petition is complete…. If the petition is deemed complete at the intake appointment, the CSD will commence its review and analysis of the petition in accordance with the standards and criteria set forth in the Charter Schools Act. (Ed. Code, § 47605.).”  (AR 15 [bold italics in original].) 

 

            Reed then explained LAUSD’s staff’s decision not to receive the EQ7 Petition as follows:

 

Consistent with the authority above that empowers the District with control of the application approval process, the District’s Charter Schools Division reviewed Equitas 7’s petition application at the intake appointment and made an appropriate determination regarding the petition’s completeness for purposes of proceeding with the review and analysis under Education Code section 47605. The District’s Charter Schools Division specifically determined that Equitas 7’s petition application was deemed incomplete because Equitas 7 failed to include all the necessary components of the Community Impact Assessment section of the New Independent Charter School Petition Application Intake Checklist (“Checklist”).  (AR 15 [bold italics and italics in original].)

 

Writ Proceedings

           

            On April 29, 2022, Petitioner filed its verified petition for writ of mandate.  Respondents have answered.  On July 8, 2022, Petitioner filed its opening brief in support of the petition and supporting declaration.  The court has received Respondents’ opposition brief and supporting declarations, Petitioner’s reply, the joint administrative record (hereafter cited as “AR”), and the joint appendix. 

 

Standard of Review; and Summary of Applicable Law

 

The petition for writ of mandate is brought pursuant to CCP section 1085.  There are two essential requirements to the issuance of an ordinary writ of mandate under Code of Civil Procedure section 1085: (1) a clear, present, and ministerial duty on the part of the respondent, and (2) a clear, present, and beneficial right on the part of the petitioner to the performance of that duty. (California Ass’n for Health Services at Home v. Department of Health Services (2007) 148 Cal.App.4th 696, 704.) “An action in ordinary mandamus is proper where … the claim is that an agency has failed to act as required by law.” (Id. at 705.)

 

Generally, mandamus is available to compel a public agency's performance or to correct an agency's abuse of discretion when the action being compelled or corrected is ministerial.”  (AIDS Healthcare Foundation v. Los Angeles County Dept. of Public Health (2011) 197 Cal.App.4th 693, 700.)  “Mandamus does not lie to compel a public agency to exercise discretionary powers in a particular manner, only to compel it to exercise its discretion in some manner.”  (Ibid.) 

 

“A ministerial act is an act that a public officer is required to perform in a prescribed manner in obedience to the mandate of legal authority and without regard to his own judgment or opinion concerning such act's propriety or impropriety, when a given state of facts exists.”  (Kavanaugh v. West Sonoma County Union High School Dist. (2003) 29 Cal.4th 911, 916.) 

 

"Even if mandatory language appears in [a] statute creating a duty, the duty is discretionary if the [public entity] must exercise significant discretion to perform the duty."'  (AIDS Healthcare Foundation v. Los Angeles County Dept. of Public Health (2011) 197 Cal.App.4th 693, 701.)  “While a writ of mandate may issue to compel compliance with a ministerial duty - an act the law specifically requires - it may not issue to compel an agency to perform that legal duty in a particular manner, or control its exercise of discretion by forcing it to meet its legal obligations in a specific way."   (Marquez v. State Dept. of Health Care Services (2015) 240 Cal.App.4th 87, 118-119.) 

 

“‘On questions of law arising in mandate proceedings, [the court] exercise[s] independent judgment’…. Interpretation of a statute or regulation is a question of law subject to independent review.  (Christensen v. Lightbourne (2017) 15 Cal.App.5th 1239, 1251.)  

 

Petitioner bears the burden of proof and persuasion in a mandate proceeding brought under CCP section 1085. (California Correctional Peace Officers Assn. v. State Personnel Bd. (1995) 10 Cal.4th 1133, 1154.) 

 

Analysis

 

            Petitioner contends that LAUSD’s Board has a ministerial duty to “receive” a charter petition “on the day the petitioner submits a petition to the district office, along with a signed certification that the petitioner deems the petition to be complete.”  (Opening Brief (“OB”) 13, citing § 47605(b).)  Because Petitioner submitted the EQ7 Petition to LAUSD and a signed certification that it deemed the petition to be complete (Ford Decl. ¶ 4; AR 324), Petitioner contends that Respondents had no discretion to refuse to receive the EQ7 Petition.  (OB 13-14.)  Respondents contend that the relevant language from section 47605(b) is not mandatory and that “District retains some discretion over charter petition receipt—namely, what constitutes a complete charter petition application to LAUSD.”  (Oppo. 12.)  The court agrees with Petitioner that section 47605(b) imposed a mandatory duty on Respondents to deem the EQ7 Petition “received” on March 30, 2022, the date it was submitted to LAUSD with a signed certificate of completeness.  The court will grant the petition. 

 

Rules of Statutory Interpretation

 

The petition raises questions of statutory interpretation.  “The rules governing statutory construction are well settled. We begin with the fundamental premise that the objective of statutory interpretation is to ascertain and effectuate legislative intent. [Citations.] To determine legislative intent, we turn first to the words of the statute, giving them their usual and ordinary meaning. [Citations.] When the language of a statute is clear, we need go no further. However, when the language is susceptible of more than one reasonable interpretation, we look to a variety of extrinsic aids, including the ostensible objects to be achieved, the evils to be remedied, the legislative history, public policy, contemporaneous administrative construction, and the statutory scheme of which the statute is a part.”  (Nolan v. City of Anaheim (2004) 33 Cal.4th 335, 340.) 

 

When interpreting a statute, the court must construe the statute, if possible to achieve harmony among its parts.  (People v. Hull (1991) 1 Cal. 4th 266, 272.)   The court “must select the construction that comports most closely with the apparent intent of the Legislature….”  (People v. Jenkins (1995) 10 Cal.4th 234, 246.) 

 

The Plain Language of Section 47605(b)

 

Section 47605(b) imposes timelines by which a governing board “shall” hold a public hearing and “shall” either grant or deny a charter petition.  These timelines are triggered by the date the governing board receives a petition.  The statute specifies when a charter petition is considered received.  A petition is deemed received by the governing board of the school district for purposes of commencing the timelines described in this subdivision on the day the petitioner submits a petition to the district office, along with a signed certification that the petitioner deems the petition to be complete.”

 

The statute defines when a charter petition is “deemed received.”  The Legislature identified only two requirements for a petition to be deemed received: (1) the petitioner submits the petition to the district office; and (2) the petitioner submits a signed certification that the petition deems the petition to be complete.  Notably, the Legislature did not state that the district board or district office may determine whether a petition is complete.  Nor did the Legislature set forth any factors or legal standard for a district board to apply to determine whether a petition is “complete.”  Rather, the Legislature only required a signed certification of completeness from the petitioner.     

 

            The only reasonable interpretation of this statutory language is that a charter petition is conclusively presumed to have been received by the district board on the day the petitioner submits the petition to the district office, along with a signed certificate of completeness.   “[C]ases construing the term ‘deemed’ have held … that the meaning of ‘deemed’ is that the deemed state of affairs is conclusively presumed to exist.”  (Parmett v. Sup.Ct. (1989) 212 Cal.App.3d 1261, 1266.) 

 

            Respondents contend that section 47605(b) is ambiguous in that the Legislature used the verb “is” rather than “shall be” or “may be” prior to the word “deemed.”  Respondents point out that the Legislature used the mandatory verb “shall” in the same subdivision at issue, but not in the sentence defining when a petition is complete.  (Oppo. 12.) The court is not persuaded by either argument. 

 

Unlike the auxiliary verb “may,” the auxiliary verb “is” does not express the possibility of an event or action.  Rather, “is” connotes a present or existing condition.  Thus, the phrase “is deemed received” connotes a conclusive standard of completeness if the two statutory requirements discussed above are met.  The Legislature’s use of the mandatory verb “shall” to define certain duties of the district board, but the phrase “is deemed received” to trigger the timelines for board action, does not suggest that the Legislature intended to create a discretionary duty to determine the date on which a petition was filed.  Rather, the statutory language shows that the Legislature sought to establish a clear and consistent standard of when a charter petition is “received” “for purposes of commencing the timelines” under which the board must act on the petition. 

 

            As argued persuasively by Petitioner, Respondents’ interpretation of section 47605(b) improperly ignores language in the statute and inserts language not present.  (Reply 3-6; see also OB 9-13.)  “When interpreting statutory language, we may neither insert language which has been omitted nor ignore language which has been inserted.”  (See People v. National Auto. and Cas. Ins. Co. (2002) 98 Cal.App.4th 277, 282.)  Respondents contend that, pursuant to section 47605(b), “the District must logically exercise discretion, per the Act and its Charter School Policies, to determine whether a charter petition application does, in fact, contain all necessary components, before commencing to process it.”  (Oppo. 13.)  Respondents make clear that they believe school district staff have such discretion.  (See Oppo. and Aguilar Decl. generally.)  However, section 47605(b) includes no language imposing duties or conferring discretion on school district staff.  The statute speaks exclusively of the mandatory duties of the “governing board.”  Moreover, the statute includes no language suggesting that the even the board may “exercise discretion” with respect to the date of receipt of a charter petition. 

 

            Respondents also construe section 47605(b) in a manner that would render statutory language superfluous.  If school districts have discretion under section 47605(b) to determine whether a charter petition is “compete,” that would render the second requirement in section 47605(b)—the petitioner’s certification of completeness—meaningless.  As discussed below, the Legislature specifically amended the statute in 2019 to add the requirement of a certification of completeness.  “[I]nterpretations which render any part of a statute superfluous are to be avoided.”  (Young v. McCoy (2007) 147 Cal.App.4th 1078, 1083.) 

 

            Based on the foregoing, the court finds the plain language of section 47605(b), as applied to this case, to be unambiguous.  The Legislature identified only two requirements for a petition to be deemed received: (1) the petitioner submits the petition to the district office; and (2) the petitioner submits a signed certification that the petition deems the petition to be complete.  The statute confers no discretion on the district board or district staff to determine whether the petition is “complete” or to refuse to receive the petition if the statutory requirements are met.  It is undisputed that Petitioner satisfied these two requirements when it submitted the EQ7 Petition and a signed certificate of completeness to LAUSD on March 30, 2022.  (See Ford Decl. ¶ 4; Aguilar Decl. ¶ 14; AR 324 [certificate of completeness]; AR 146-12329 [entire petition].)  Pursuant to statute, the EQ7 Petition is conclusively “deemed received” on that date.  Respondents lacked discretion to refuse to receive the petition. 

 

Legislative History of Section 47605(b) and Public Policy

 

“If the statutory language is unambiguous, we presume the Legislature meant what it said, and the plain meaning of the statute controls.”  (Conservatorship of Whitley (2010) 50 Cal.4th 1206, 1214; see also Friends of Juana Briones House v. City of Palo Alto (2010) 190 Cal.App.4th 286, 303-304 [“If the language “is clear and unambiguous our inquiry ends”.])  Because section 47605(b) is unambiguous as applied to this case, the plain language controls and the court need not consider extrinsic aids, including legislative history. 

 

Even if the court were to consider legislative history, the court would reach the same conclusion. Prior to 2020, section 47605(b) stated that the timeline for the board to act on the petition commenced when the board received the petition, but it did not specify how or when the board received it.  Thus, the prior version of section 47605(b) was ambiguous with respect to when a board “receives” a charter petition.  That ambiguity was clarified through a legislative amendment in 2019, which enacted the operative language analyzed above.  (See 2019 Cal. Legis. Serv. Ch. 486 (A.B. 1505) (WEST).)  Consistent with the court’s analysis of the plain language, the legislative history shows intent by the Legislature to establish a clear standard governing receipt of a charter petition by a district board.

 

Respondents point to a senate committee report which describes how a proposed version of Assembly Bill 1505 would amend the Charter Schools Act to give school districts “greater authority to choose which charter schools are approved in their community.”  (Oppo. 15, citing RJN Exh. A at 5.)  This legislative history is inapposite.  Respondents cite no language from this report suggesting that the amended provision regarding the date of receipt of the petition (i.e., “is deemed received”) was intended to confer discretion on the district to determine when a petition is received.  Notably, the report also states that petitioners “interested in creating a charter school must adhere to a state prescribed application process,” not a local one.  (RJN Exh. A at 6 [bold italics added].)  This report does not support Respondents’ interpretation of section 47605(b).

 

Respondents make public policy arguments why LAUSD staff should have discretion under section 47605(b) to determine whether a charter petition is “complete” and should be deemed received.  (Oppo. 13-20.)  While these policy arguments are debatable, they are in any event misdirected given the clear and unambiguous language of the statute.  These arguments are best made to the Legislature.  

 

Based on the foregoing, section 47605(b) imposed a mandatory duty on Board to deem the EQ7 Petition received on March 30, 2022 and to commence the statutory process specified in section 47605(b) on that date. 

 

LAUSD’s Policy Conflicts with Section 47605(b) and is Preempted

 

Despite the mandatory duty imposed by state law to deem the EQ7 Petition received on March 30, 2022, Respondents contend that LAUSD has promulgated lawful policies and procedures governing the “receipt” of charter petitions and that LAUSD complied with those policies in this case.  (Oppo. 14-16.)  Respondents contend that these policies are not preempted by state law, including section 47605(b).  (Id. 16-20.)  Petitioner contends that any contrary policies of LAUSD are preempted by state law.  (OB 11-14.) 

 

“‘Under article XI, section 7 of the California Constitution, '[a] county or city may make and enforce within its limits all local, police, sanitary, and other ordinances and regulations not in conflict with general laws.' If otherwise valid local legislation conflicts with state law, it is preempted by such law and is void.  A conflict exists if the local legislation duplicates, contradicts, or enters an area fully occupied by general law, either expressly or by legislative implication. Local legislation is 'duplicative' of general law when it is coextensive therewith.  Similarly, local legislation is 'contradictory' to general law when it is inimical thereto. Finally, local legislation enters an area that is 'fully occupied' by general law when the Legislature has expressly manifested its intent to 'fully occupy' the area, or when it has impliedly done so in light of one of the following indicia of intent: '….”  (San Diego Gas & Electric Co. v. City of Carlsbad (1998) 64 Cal.App.4th 785, 792-793.)

 

Similarly, Education Code section 35160 states: “On and after January 1, 1976, the governing board of any school district may initiate and carry on any program, activity, or may otherwise act in any manner which is not in conflict with or inconsistent with, or preempted by, any law and which is not in conflict with the purposes for which school districts are established.”

 

A local ordinance contradicts state law when it is inimical to or cannot be reconciled with state law.”  (O’Connell v. City of Stockton (2007) 41 Cal.4th 1061, 1068.)

 

For the specific issue raised by this writ petition, the preemption analysis is straightforward and requires only a brief discussion.  As discussed above, section 47605(b) imposed a mandatory duty on Board to deem the EQ7 Petition received on March 30, 2022.  Contrary to Respondents’ assertion, section 47605(b) conferred no discretion on LAUSD staff to determine if the EQ7 Petition was complete or to refuse to “receive” the petition.  Respondents cite LAUSD Policy and Procedures for Charter Schools, last amended January 25, 2022.  (Oppo. 15, citing AR 27.)  The Policy and Procedures state, inter alia, that “[a]t the intake appointment, CSD staff will determine if the petition is complete.”  (AR 27.)  To the extent the Policy and Procedures can be interpreted to confer discretion on LAUSD staff to refuse to receive a charter petition that satisfies the two requirements of section 47605(b) discussed above (i.e., submission to district office and signed certificate of completeness), the Policy and Procedures directly contradict section 47605(b) and are inimical thereto.  Section 47605(b), as interpreted by the court, cannot be reconciled with a LAUSD policy that confers discretion on CSD staff to refuse to “receive” a charter petition that complies with the two submission requirements discussed above.  “If otherwise valid local legislation conflicts with state law, it is preempted by such law and is void.”  (San Diego Gas & Electric Co., supra, 64 Cal.App.4th at 792-793.)

 

Respondents contend that the relevant part of the LAUSD Policy and Procedures is “reasonable”; that the Policy and Procedures were lawfully promulgated; and the Charter Schools Act did not fully occupy the field with respect to the application process for charter schools.  (Oppo. 16-19.)  The court need not analyze these contentions.  As discussed, section 47605(b) imposes a mandatory duty on Board to deem the EQ7 Petition received on March 30, 2022.  Any contrary policy of LAUSD under which LAUSD did not have a mandatory duty to deem the petition received conflicts with state law and is preempted. 

 

Based on the foregoing, section 47605(b) imposed a mandatory duty on Board to deem the EQ7 Petition received on March 30, 2022.  Any contrary local policy of LAUSD is preempted and void. 

 

Remedy

 

            Writ Directing Board to Receive Petition and Commence Statutory Process

 

Board has a clear, present, and ministerial duty to deem the EQ7 Petition received as of March 30, 2022, and to hold a hearing on the EQ7 Petition, to grant or deny the charter, and perform other duties within the deadlines specified in section 47605(b).  Since the petition was deemed received on March 30, 2022, the court agrees with Petitioner that Respondents should be ordered to immediately commence the statutory process and timelines set forth in section 47605(b).  (OB 14-15.)  The statutory timelines will commence on the date the writ is issued by the court.  Accordingly, the court will grant the requested relief in paragraph 1(a)-(c) of the prayer and at page 15 of the opening brief.  (See OB 15:10-18.)

 

Writ Directing Respondents to Set Aside a Policy

 

In addition to the writ requiring Respondents to receive the EQ7 Petition, Petitioner also requested in the prayer a writ directing Respondents to “[s]et aside any District-promulgated requirement, restriction or limitation inconsistent with or contrary to the mandate of Education Code section 47605(b) requiring that a charter petition is received by the District Board in accordance with that statute.”  (Pet. Prayer ¶ 1.)

 

However, Petitioner did not address this prayer for relief in the opening brief or reply.  The court considers the issue forfeited for purposes of this writ petition.  (Nelson v. Avondale HOA (2009) 172 Cal.App.4th 857, 862-863 [argument waived if not raised or adequately briefed]; Pfeifer v. Countrywide Home Loans, Inc. (2012) 211 Cal.App.4th 1250, 1282 [same].) 

 

Conclusion

 

 The petition is GRANTED IN PART.  The court will grant the requested relief in paragraph 1(a)-(c) of the prayer and page 15 of the opening brief.  Specifically, the court will grant a writ directing Respondents to “(1) receive Equitas’s EQ7 Petition and certification of completeness in accordance with Education Code section 47605(b); (2) commence the 60-day timeline for the District Board to hold a public hearing on the provisions of the charter, and in fact hold that public hearing in accordance with Education Code section 47605; and, (3) commence the 90-day timeline for the District Board to either grant or deny the charter, and in fact take that action one way or the other in accordance with Education Code section 47605.”  (OB 15:10-18.)  The statutory timelines in section 47605(b) will commence on the date the writ is issued by the court. 

 

Petitioner is directed to lodge and serve a proposed form of judgment and a proposed form of writ after meeting and conferring with Respondent regarding any objections as to form.  Petitioner is to lodge a declaration along with the proposed judgment and proposed writ in accordance with LASC local rules, Rule 3.231(n).