Any Act Necessary? The Fifth Appellate District’s Decision in Inzana v. Turlock Irrigation District
by Callie Lee Lindemann*
In June 2019, the Fifth Appellate District decided Inzana v. Turlock Irrigation District Board of Directors1 which provides important new appellate analysis and authority regarding the scope of special district power and the nature of fundamental vested property rights. This article provides an overview of Inzana, analyzes the court’s reasoning, and assesses the potential application of the case to interpretation of other special district powers. This article concludes that Inzana is a measured decision that reasonably protects special district property without unduly expanding special district authority.
I. FACTS OF INZANA