Marin Healthcare District v. Sutter Health

Opinion

KOLKEY, J.

In this action, we must determine whether the judicially created doctrine enunciated in Hoadley v. San Francisco (1875) 50 Cal. 265 (Hoadley)—that the statute of limitations does not apply to actions by the state to recover property dedicated for public use against an adverse possessor—should be extended to bar the application of the statute of limitations to the state’s action to void a lease of public-use property. Because the purpose of the Hoadley doctrine is to prevent public-use property that the state cannot directly alienate from being indirectly alienated through the…