_____________________
_____________________
_____________________
_____________________
By Brian Hews
Publisher | Follow X
December 19, 2025
Two weeks ago, Los Cerritos Community News launched High Stakes, Dirty Water, Red Flags, a multi-part investigative series revealing that for more than four years Central Basin Director Juan Garza quietly operated the California Cities for Self-Reliance Joint Powers Authority (JPA), a taxpayer-funded agency, through Bellflower-based Six Heron, his privately owned public-relations and government-relations firm.
That private control, combined with Garza’s renewal of his contract as the JPA’s executive director while simultaneously serving as an elected water official for Central Basin, has now placed his Central Basin Municipal Water District seat in legal peril.
Part One documented how Garza used his personal Six Heron email, company cellphone, and Bellflower P.O. Box as the JPA’s operational and procurement pipeline, effectively turning a public agency into a one-man operation.
Publishing last week, Part Two exposed how that private control of the JPA collided directly with Garza’s elected authority at the Central Basin Municipal Water District, where he votes on water rates, infrastructure, and policies affecting the very cities that fund his JPA executive-director salary — including Hawaiian Gardens, a JPA member city within his own Central Basin division.
Part Three now turns to the legal trigger created by that arrangement: whether Garza’s negotiated renewal of his salaried JPA employment contract activated Government Code 1099’s automatic-vacancy rule.
Under Government Code 1099, when a public official assumes or renews a second public office that is incompatible with the first, the statute is automatic: the first office is deemed vacated by operation of law. No vote is required. No finding of misconduct is necessary.
Once the Contract Renewed, the Clock Stopped
Garza has served as Executive Director of the JPA since March 2020. He joined the Central Basin Municipal Water District board in December 2020.
Since then, he has renewed his JPA employment contract while serving as a Central Basin Water Director and as Central Basin’s delegate to the Metropolitan Water District [MWD].
The only question is whether the duties of the two positions create divided loyalty or overlapping authority. In Garza’s case, the divided loyalty and overlapping authority is direct.
The JPA’s own mission underscores the conflict. The JPA that Garza runs as executive director represents card rooms in Bell Gardens, Commerce, Compton, and Hawaiian Gardens — all cities that are Central Basin customers. Hawaiian Gardens sits within Garza’s own Central Basin Division 4. Through the JPA, Garza is paid $6,744 per month to advocate for those card rooms, including lobbying, communications, and legal action to protect their financial and regulatory interests.
Through Central Basin, Director Garza simultanoeusly votes on water rates, infrastructure spending, and policies that directly affect those same cardroom cities. Through MWD, he votes on wholesale water decisions that flow down to Central Basin and those same cardroom cities.
Those roles are incompatible on their face. And when they collide, Government Code 1099 does not ask whether the official acted improperly. It asks only whether the duties could conflict.
The timing makes the issue decisive. Garza was already the JPA’s executive director when he took the oath at Central Basin. He later renewed his JPA contract while serving as a water director. Under Government Code 1099, renewing an incompatible office is treated the same as assuming one. Each renewal resets the legal trigger.
If Garza’s JPA role is deemed a public office rather than exempt employment — as Attorney General opinions have repeatedly found when an official manages public funds, oversees operations, executes contracts, and directs advocacy — then his Central Basin seat would have been vacated automatically the moment he renewed that contract. Because his MWD seat exists only by virtue of his Central Basin position, forfeiture would extend to both.
When asked to cite any statute or Attorney General opinion expressly authorizing a Central Basin director to simultaneously serve as the paid executive director of a lobbying JPA representing Central Basin customer cities, Garza did not identify one. Instead, he repeatedly asserted that his role is exempt under Government Code sections 1099(c) and (d), without addressing the contract renewals, the divided loyalties, or the automatic-vacancy rule.
But Attorney General precedent does not support that reading.
The exemption Garza relies on is the “employment” exception under Government Code section 1099 under (c) and (d), which allows an official to hold a public office and a truly subordinate employment position simultaneously. But that exception is narrow. It does not apply when the second role (Garza JPA) involves policymaking, advocacy, budget authority, procurement, independent judgment, or control over public resources. Managing a JPA — particularly one funded by cities whose interests intersect with the official’s other agency — goes well beyond exempt employment as defined by the AG and the courts.
Garza has also argued that the Metropolitan Water District Act authorizes his dual service. It does not. Section 56 permits a member agency to appoint one of its directors as its MWD representative. It does not authorize that director to simultaneously hold a separate, paid executive office whose duties collide with Central Basin and MWD rate and policy decisions. Nothing in the MWD Act overrides Government Code 1099.
An Attorney General opinion, 90 Ops.Cal.Atty.Gen. 49 (2007), cuts directly against Garza’s legal claims.
The opinion makes clear that Government Code 1099 applies broadly to public offices, including water district directors and MWD representatives. Authorization to serve as a member agency’s representative on the MWD board does not immunize an official from incompatibility created by other, separate offices. The analysis turns on real-world duties and divided loyalties, not job titles or labels, and when incompatibility exists, forfeiture is automatic. Just as important, the opinion does not say that employment labels defeat 1099, that appointed roles are exempt, that joint powers authorities are insulated from scrutiny, or that advocacy or lobbying bodies are somehow outside the statute.
Section 56 of the MWD Act authorizes only MWD representation — nothing more. And the JPA Garza runs is not an MWD member agency, not a subordinate arm of Central Basin, but a separate public entity formed under Government Code 6500 with its own board, contracts, budget, procurement, and mission. Under the Attorney General’s framework, that role must be evaluated independently — and it is not shielded by the MWD Act.
Government Code 1099 is self-executing. If the offices are incompatible, forfeiture occurs by operation of law — regardless of whether the official agrees, regardless of whether the board acts, and regardless of whether the official continues to vote.
The implications are not theoretical. Central Basin’s recent governance failures make the legal status of its board members decisive. Under Government Code 1099, Garza forfeited his seat the moment he renewed his JPA contract, placing every subsequent board action involving his vote under a legal cloud. When combined with the continued participation of Board President Nem Ochoa and Director Joanna Moreno—who remain on the board after their terms expired in 2024 and now 2025, in direct violation of AB 1794 and the agency’s own Water Code—the result is not a technical defect but a governance breakdown. What remains is a board whose composition itself is legally suspect, calling into question the validity of its actions, contracts, and decisions.
Part Three of High Stakes, Dirty Water, Red Flags laid out the legal trigger, the timeline, and the questions Garza has refused to answer. What comes next no longer rests with board members, but with those empowered to enforce the law — including the Attorney General and any party with standing to seek a quo warranto determination.
Part Four answers the unavoidable next question: what happens to everything the board did after it was no longer lawfully constituted. Central Basin was operating without a legally valid quorum. Any action requiring their votes — including hiring the General Manager, approving contracts, authorizing payments, setting policy direction, or certifying board actions — becomes vulnerable to challenge as void or voidable.
Subscribe to get the latest posts sent to your email.
You must be logged in to post a comment Login