The First Appellate District affirmed a judgment. The court held that a county district attorney had no affirmative and nondiscretionary duty to investigate and prosecute alleged crimes related to the expenditure of Proposition 39 school bond funds.

Jeffrey Gananian sent a letter to the San Mateo County District Attorney alleging misconduct by a local school district and former district superintendent in violation of the Political Reform Act of 1974 (PRA). Gananian alleged the district and former superintendent had violated PRA reporting requirements by failing to disclose financial conflicts of interest with regard to their use of recently issued school bonds. The district attorney declined to pursue a cause of action.