CITIZENS FOR RESPONSIBLE OPEN SPACE v. SAN MATEO COUNTY LOCAL AGENCY FORMATION C
Where municipal district annexed property pursuant to Cortese Knox Hertzberg Act, trial court's decision that county local agency formation commission substantially complied with Government Code Sec. 57026(e) was not error even though commission failed to comply with statute's requirements that public notice of protest hearing set forth statement of reasons for annexation because record was replete with references to widespread notice of annexation proceedings and reasons for annexation, and challengers failed to show prejudice under Sec. 56107(a). Potential ambiguities in maps of annexed territory were not prejudicial where map sufficiently described exterior areas of subject area, and errors were insignificant; no evidence existed that residents of annexed area failed to receive proper notice or did not understand that area was included in proposed annexation; and challengers failed to show prejudice. Annexation was properly finalized without an election under Sec. 57075(a)(2) where less than 25 percent of registered voters in affected area protested annexation. Commission did not violate Secs. 57052 and 56707 which require that commission determine amount of written protests filed and not withdrawn, and compare them against total registered voters in affected area where it delegated task to elections department because department was government division competent to perform task. Commission did not err in counting total number of registered voters at end of protest period rather than at commencement of annexation procedures where it had a reasonable explanation for doing so, and matter was within commission's discretion. Commission properly excluded protests that did not include protesters' residence address under Sec. 57051, and trial court's determination that requirement was inconsistent with act because some residents' residential address differed from their mailing address was error.
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