I do think that Pliny has a mystique that gets it votes, as has every other "top beer". Dogfish head 90 won it a few years in a row, but they distribute far and wide. The one that gets me was Alaskan Smoked porter, it won a couple years in a row and its distribution was very limited. The other thing to think about is how many homebrewers live in California... Quaff, Doze, the Maltose Falcons and the Brewing Network (not all are in California, but I would bet that a substantial number are), are some of the most populous homebrew clubs and they are all in CA... I think the days of a non-California beer winning best beer in America will be few and far between.