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NATURIST ACTION COM. v. DEPARTMENT OF PARKS & RECREATION

No. G040929.

175 Cal.App.4th 1244 (2009)

NATURIST ACTION COMMITTEE et al., Plaintiffs and Respondents, v. DEPARTMENT OF PARKS AND RECREATION et al., Defendants and Appellants.

Court of Appeals of California, Fourth District, Division Three.

June 25, 2009.

Attorney(s) appearing for the Case

Edmund G. Brown, Jr., Attorney General, Mary E. Hackenbracht, Assistant Attorney General, Carol A. Squire and Deborah Fletcher, Deputy Attorneys General, for Defendants and Appellants.

Law Office of Elva P. Kopacz and Elva P. Kopacz for Plaintiffs and Respondents.

OPINION

RYLAARSDAM, Acting P. J.—

This appeal raises the question of whether an internal policy memorandum issued by defendant Department of Parks and Recreation (department) rises to the level of a regulation and thus cannot be revoked without satisfying the procedural requirements of the Administrative Procedure Act (APA; Gov. Code, § 11340 et seq.; all further statutory references are to this code unless otherwise stated). We...

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