
In Moving Oxnard Forward v. City of Oxnard (2025), the California Court of Appeal upheld the City’s $45 million lease revenue bond issuance, rejecting claims that voter approval was required under the state constitution.
The court applied the Offner-Dean rule, holding that lease payments tied to the City’s use of property are contingent obligations—not unconstitutional debt. It also confirmed the City’s compliance with the Marks-Roos Act, finding sufficient public benefit and no procedural violations.
Key Takeaway: The decision reinforces the legality of using lease-leaseback financing through joint powers authorities.