City Council Staff Report Page 1 of 5 September 8, 2026 Staff Report
Agenda Item No. 3.4
DATE: September 8, 2026
TO: Honorable Mayor and Members of the City Council
FROM: Joan Malloy, City Manager
SUBJECT: Review the League of California Cities 2026 Annual Conference Resolution and Provide Direction to the City’s Voting Delegate
EXECUTIVE SUMMARY
The City Council is asked to review Resolution No. 1 submitted by the City of Murrieta for consideration at the League of California Cities 2026 Annual Conference and Expo and provide direction to the City’s designated voting delegate regarding the City’s position on the resolution.
Resolution No. 1 calls on the League of California Cities to support the development and advancement of a state constitutional amendment or other legislative, policy, or ballotbased strategy to restore and strengthen local authority over housing and land-use matters. The resolution also calls for consideration of a statewide working group or other appropriate committee to evaluate and develop potential strategies.
The resolution may be amended during the League of California Cities policy committee and Resolutions Committee review process. Accordingly, the City Council may also provide direction regarding the voting delegate’s discretion if amendments are made before the resolution is presented to the General Assembly.
STRATEGIC PLAN ALIGNMENT
This action is not aligned with the strategic plan.
BACKGROUND
The League of California Cities convenes a General Assembly during its Annual Conference and Expo to consider resolutions that may establish League policy. Each member city is entitled to cast one vote through a voting delegate formally designated by its city council.
The League of California Cities received one general resolution for consideration at the 2026 Annual Conference and Expo. In its August 10, 2026, resolution packet, the League encouraged each member city council to review the resolution and determine a position Agenda Item No. 3.4
City Council Staff Report Page 2 of 5 September 8, 2026 so that its voting delegate may represent the city’s position during the General Assembly.
Resolution No. 1 was submitted by the City of Murrieta and was accompanied by eight letters of concurrence from cities and individual city officials. The resolution has been referred to the League’s Housing, Community, and Economic Development Policy Committee.
The resolution review process is scheduled as follows:
1. The Housing, Community, and Economic Development Policy Committee will consider the resolution on September 17, 2026.
2. The Resolutions Committee will consider the resolution and the policy committee’s recommendation on September 24, 2026.
3. The General Assembly will convene on September 25, 2026, at 8:30 a.m. at the Anaheim Convention Center.
As of the September 8, 2026, City Council meeting, neither the Policy Committee nor the Resolutions Committee will have acted on the resolution. Both committees may approve, disapprove, amend, take no action on, or refer the resolution for further study. A resolution that is not forwarded by the applicable committees will not proceed to the General Assembly.
DISCUSSION
Resolution No. 1
Resolution No. 1 is titled:
“A Resolution of the General Assembly of the League of California Cities Calling for a Working Group to Consider a State Constitutional Amendment or Other Form of Initiative to Ensure Final Local Authority Over Housing and Land Use Decisions.”
If approved, Resolution No. 1 would establish the League of California Cities' policy supporting the development and advancement of a state constitutional amendment or other legislative, policy, or ballot-based strategy to restore and strengthen local authority over housing and land use matters. The matters identified in the resolution include general plans, housing elements, zoning, density, design and development standards, project siting, and the approval or denial of housing development applications.
The resolution provides that any constitutional amendment or alternative strategy should preserve the State’s authority to establish broad statewide housing goals and enforce constitutional and civil rights, fair housing requirements, building and life-safety standards, and generally applicable environmental protections.
At the same time, the resolution seeks to protect cities from state actions that:
1. Compel approval of housing developments that are inconsistent with locally adopted requirements;
2. Override locally adopted zoning or density standards; or Agenda Item No. 3.4
City Council Staff Report Page 3 of 5 September 8, 2026
3. Invalidate local housing or land use decisions when a city has planned in good faith to accommodate its regional housing needs allocation and maintains adequate housing capacity at all income levels.
The resolution also calls for the League of California Cities to consider establishing a statewide working group or other appropriate committee to conduct legal, fiscal, and policy analyses; engage cities and other stakeholders; and build a statewide coalition.
The resolution identifies the November 2030 General Election, or another reasonable timeframe determined by the working group, as a potential target for advancing any resulting strategy.
Approval of Resolution No. 1 would not itself amend the California Constitution or place a measure on the statewide ballot. It would establish League policy supporting the development and evaluation of potential constitutional, legislative, policy, or ballot-based strategies.
Policy and Implementation Considerations
The League of California Cities staff analysis notes that the organization’s existing policies support local self-governance, local autonomy, and the principle that local zoning is a primary function of cities. Resolution No. 1 would build on existing policies by directing the League to evaluate potential mechanisms to strengthen local authority over housing and land-use decisions.
The League’s analysis also identifies several legal and practical considerations. State law may preempt local ordinances adopted under a city’s police power, and charter city authority over municipal affairs may be limited when a subject is determined to be a matter of statewide concern. Any working group would therefore need to evaluate whether a proposed constitutional change would constitute an amendment or a broader constitutional revision, as those approaches involve different legal processes.
Resolution No. 1 does not prescribe a specific constitutional amendment, legislative proposal, or ballot measure. The policy and fiscal implications would depend on the strategy ultimately developed. The League’s staff analysis states that the resolution itself would not have a significant direct fiscal impact, but that subsequent advocacy, ballot qualification, coalition-building, and campaign activities could incur high costs.
Council Direction
The City Council may provide one of the following directions to the City’s voting delegate:
1. Support Resolution No. 1;
2. Oppose Resolution No. 1;
3. Take no position on Resolution No. 1; or
4. Provide conditional direction based on specified amendments or policy considerations.
Because the Housing, Community, and Economic Development Policy Committee and the Resolutions Committee may amend the resolution after the September 8 City Council Agenda Item No. 3.4
City Council Staff Report Page 4 of 5 September 8, 2026 meeting, the Council may also authorize the voting delegate to exercise reasonable discretion regarding amendments that are substantially consistent with the Council’s direction.
The League’s procedures also allow petitioned resolutions to be introduced during the Annual Conference if the required number of voting delegates sign the petition. Petitioned resolutions are not available for advance review at this time. The Council may determine whether the voting delegate should have discretion to consider any petitioned resolution presented at the General Assembly.
Any direction provided by the City Council would apply to the designated alternate voting delegate if the alternate serves as the City’s voting representative during the General Assembly.
FISCAL IMPACT
There is no direct fiscal impact to the City associated with reviewing Resolution No. 1 and providing direction to the City’s voting delegate.
The League of California Cities staff analysis states that the resolution itself would not have a significant direct fiscal impact. However, future actions arising from the proposed working group, including legal analysis, legislative advocacy, ballot qualification, coalition development, or campaign activity, could involve high costs. This action does not authorize any City expenditure related to those potential future activities.
RECOMMENDATION
The City Council should review Resolution No. 1 and provide direction to the City’s voting delegate regarding whether to support, oppose, or take no position on the resolution, including any direction regarding amendments or petitions to resolutions that may be presented during the League of California Cities 2026 Annual Conference and Expo.
Staff recommends that the City Council allow the voting delegate to use their discretion regarding the final vote. The resolution will have been reviewed by two committees before a recommendation is presented to the General Assembly. If there is a recommendation to support, the resolution (as currently written) only seeks "that the League of California Cities consider establishing a statewide working group or other appropriate committee(s) to evaluate and develop a proposed constitutional amendment or other legislative, policy, or ballot-based strategies to restore and strengthen local authority over housing and land use matters...” There is no obligation to support a constitutional amendment or other outcome from a working group or committee.
Prepared by: Thai Nam Pham, City Clerk
Submitted by: Thai Nam Pham, City Clerk
Agenda Item No. 3.4
City Council Staff Report Page 5 of 5 September 8, 2026 Attachments
1. League of California Cities 2026 Resolution Packet