Sierra Club v. San Joaquin Local Agency Formation Commission

Opinion

WERDEGAR, J.

In Alexander v. State Personnel Bd. (1943) 22 Cal.2d 198 [137 P.2d 433] (Alexander), we held that when the Legislature has provided that a petitioner before an administrative tribunal “may” seek reconsideration or rehearing 1 of an adverse decision of that tribunal, the petitioner always must seek reconsideration in order to exhaust his or her administrative remedies prior to seeking recourse in the courts. The Alexander mle has received little attention since its promulgation, and several legal scholars and at least one Court of Appeal have expressed the belief that the…