In what circumstances will the California Supreme Court hold that the cost of constructing a new courthouse is not subject to the constitutional debt limit?

In County of Los Angeles v. Byram (1951) 36 Cal.2d 694, 227 P.2d 4, the high court held the cost of constructing a courthouse was not subject to the constitutional debt limit, because the county had a legal duty, imposed by state law, to provide "adequate quarters" for the courts. (Id. at p. 699, 227 P.2d 4.) This duty was enough to take the matter outside the constitutional debt limit, even though the county retained wide discretion regarding what kind of courthouse to construct and at what cost.