California, United States of America
The following excerpt is from Laidlaw Environmental Services, Inc., Local Assessment Com. v. County of Kern, 44 Cal.App.4th 346, 51 Cal.Rptr.2d 666 (Cal. App. 1996):
Although it was determined that a park board member was a public officer under the stated requirements of permanence and sovereignty, the circumstances presented there were much different than those extant here. The park board members were "elected" for two-year terms and served until their successors were "appointed." (City Council v. McKinley, supra, 80 Cal.App.3d at p. 210, 145 Cal.Rptr. 461.) Accordingly, it was concluded the office was neither transient nor occasional. (At pp. 210-211, 145 Cal.Rptr. 461.) The court also concluded:
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