The California Attorney General, Rob Bonta, has granted permission for a lawsuit against Jaclyn LaBarbera, a trustee of the Anderson Union High School District Board. The lawsuit, proposed by Jeffrey Carr, seeks to remove LaBarbera from her position due to her simultaneous service on both the Anderson Union High School District Board and the Shasta County Board of Education. This decision, made on June 25, 2026, raises important questions about public office compatibility and could have implications for governance in educational institutions.
The case revolves around Government Code section 1099, which prohibits public officeholders from simultaneously holding incompatible offices. Carr argues that LaBarbera's dual roles create a conflict of interest that could undermine her ability to serve effectively in either position. The Attorney General's decision to allow the lawsuit to proceed underscores the importance of ensuring that public officials maintain undivided loyalty to their respective offices.
Background
The Anderson Union High School District, located in Shasta County, serves approximately 1,500 students across six schools. It is governed by a five-member board of elected trustees. LaBarbera was first elected to this board in November 2022 and is set to serve until December 2026. In November 2024, while still serving on the School District Board, she was elected to a four-year term on the Shasta County Board of Education.
The Shasta County Board of Education oversees educational programs and services in the county, working closely with the County Superintendent of Schools. This board plays a significant role in the governance of school districts within its jurisdiction, including the Anderson Union High School District. Carr's application for a quo warranto action claims that LaBarbera's simultaneous service on both boards violates the law and that her position on the School District Board should be forfeited.
LaBarbera has opposed the application, arguing that the two offices are not incompatible and that no prior legal opinion has deemed them so. She contends that no actual conflict has arisen during her time in both positions and that allowing the lawsuit to proceed would disrupt ongoing educational governance.
The Ruling
The Attorney General ruled that there is a substantial legal issue regarding LaBarbera's simultaneous holding of two public offices. The ruling states, "We conclude there is a substantial legal issue regarding whether LaBarbera is simultaneously holding incompatible public offices." This decision allows Carr to pursue his quo warranto action against LaBarbera.
The ruling emphasizes the importance of public interest in resolving potential conflicts of loyalty among public officials. The Attorney General noted that the application for leave to sue was granted because it serves the public interest and addresses a significant legal question. The ruling also highlights the potential for conflicts arising from LaBarbera's dual roles, stating, "A public officer shall be deemed to have forfeited the first office upon acceding to the second."
Impact
This ruling has significant implications for public officeholders in California, particularly those in educational governance. If the court ultimately finds that LaBarbera's positions are indeed incompatible, it could set a precedent for future cases involving dual officeholders. It emphasizes the necessity for public officials to avoid situations where their duties may conflict, thereby ensuring that they can serve their constituents effectively.
The decision also sheds light on the legal framework surrounding public office compatibility. It reinforces the principle that public officials must act with undivided loyalty to their respective offices, and that potential conflicts of interest must be addressed proactively. This case may prompt other public officials to review their own positions to ensure compliance with Government Code section 1099.
What's Next
The lawsuit against LaBarbera can now proceed in court. The outcome may lead to her removal from the Anderson Union High School District Board, depending on the court's interpretation of the law regarding incompatible offices. There are no indications of related cases pending that could affect this ruling.