HomeMy WebLinkAboutMINUTES - 03051996 - C20 ' I
C. �
TO: BOARD OF SUPERVISORS Contra
FROM: PHIL BATCHELOR, COUNTY ADMINISTRATOR Costa
County
DATE: February4
29 1996
.req_Ceco)U C'
SUBJECT: LEGISLATION: SB 1590 (O'Connell) - MAKING PROPOSITION 62
REQUIREMENTS PROSPECTIVE
SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMENDATION:
ADOPT a SUPPORT position on SB 1590 by Senator Jack O'Connell, which would
provide that the decision of the California Supreme Court in Santa Clara County
Transportation Authority v. Guardino, 11 Cal. 4th 220, shall not be applicable to any
action in which the validity of a tax or tax increase is contested, if the ordinance or
resolution imposing or increasing the tax was adopted prior to December 14, 1995.
BACKGROUND:
The decision of the California Supreme Court in the Santa Clara County
Transportation Authority case surprised most local government officials because it
appears to be contrary to the court of appeal decision in the Woodlake decision,
which had been cited without question in the Supreme Court's decision in Rossi v.
Brown. Local governments relied on the Woodlake decision, which determined that
Proposition 62's voter approval requirement for a general tax imposed by a local
government violated the provision of the California Constitution prohibiting a
referendum of a tax levy.
Senator Jack O'Connell has introduced SB 1590 which would recognize the reliance
of local governments on the Woodlake decision and provide that the decision on
Proposition 62 is not retroactive and would, therefore, control only future new
general taxes or increases in general taxes.
CONTINUED ON ATTACHMENT: YES SIGNATURE: 7�114
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
.L APPROVE OTHER
SIGNATURE(S):
ACTION OF BOARD ON March S. 1996 APPROVED AS RECOMMENDED OTHER X
IT IS BY THE BOARD ORDERED this matter is REFERRED to the Finance Committee.
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A TRUE
X UNANIMOUS(ABSENT III ) AND CORRECT COPY OF AN ACTION TAKEN
AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN.
ATTESTED March 5, 1996
Contact: PHIL BATCHELOR,CLERK OF THE BOARD OF
cc: SUPERVISORS AND COUNTY ADMINISTRATOR
See Page 2
BY Lj I B ,DEPUTY
Contra Costa County has in place a transient occupancy tax, real estate transfer tax
and business license tax, all of which might be in jeopardy if the provisions of
Proposition 62 were determined to be retroactive. Senator O'Connell is seeking as
much local government support as possible. It is recommended that the Board of
Supervisors go on record in support of SB 1590 in order to protect existing taxing
authority and revenue, recognizing that future increases in these taxes or the
imposition of new taxes will require voter approval under the Santa Clara County
Transportation Authority decision.
cc: County Administrator
County Auditor-Controller
County Counsel
Les Spahnn: Heim, Noack, Kelly & Spahnn
1121 L Street, Suite 100
Sacramento, CA 95814
-2-
SENATE BILL No. 1590
Introduced by Senator O'Connell
(Principal coauthors: Senators Craven and Solis)
(Coauthor: Senator Beverly)
February 16, 1996
An act to add Section 53716 to the Government Code,
relating to taxation.
LEGISLATIVE COUNSEL'S DIGEST
SB 1590, as introduced, O'Connell. Local taxation: court
l decision: prospective application.
Existing law requires the imposition of a general tax by a
local government or district to be approved by a majority of
the voters voting on the tax at an election.
This bill would make the decision of the California Supreme
Court in Santa Clara County Transportation Authority v.
Guardino (1995), 11 Cal. 4th 220, in which the court upheld
the validity of this general tax voter approval requirement,
inapplicable to any tax that was first imposed.or increased by
an ordinance or resolution adopted prior to December 14,
1995.
Vote: majority. Appropriation: no. Fiscal committee: yes.
State-mandated local program: no.
The people of the State of California do enact as follows.-
1 SECTION I. The Legislature hereby finds and
2 declares as follows: -
3 (a) In City of Woodlake v. Logan, 230 Cal. App. 3d 1058
4 (hereafter Woodlake) , a California court of appeal
99
I
SB 1590 — 2 -
1
2 -1 determined that Proposition 62's voter approval
2 requirement for a general tax imposed by a local
3 government violated the provision of the California
4 Constitution prohibiting a referendum of a tax levy. The
5 analysis of this case was cited without question in the
6 California Supreme Court's decision in Rossi v. Brown, 9
7 Cal. 4th 688 (hereafter Rossi) .
8 (b) The rule of law set forth in Woodlake. was
9 consistent with a long line of cases that held that the
10 California Constitution provided no power of referenda
11 or voter approval requirement with respect to general
12 tax measures (see, e.g. City of Westminister v. County of
13 Orange, 204 Cal. App. 3d 623) .
14 (c) Local governments relied extensively upon the
15 longstanding principles reiterated in the Woodlake case
16 in enacting tax measures and pledging the anticipated tax
17 revenues to the repayment of bonds, to development
18 projects of benefit to the community, to payment of
19 long-term contractual obligations, and to the provision of
20 services to the community.
21 (d) Many of these tax measures were enacted in
22 response to reallocations of property tax revenue and
23 other revenue losses resulting from actions taken by the
24 state in response to its own budgetary problems during
25 the last several years.
26 . (e) The Woodlake case remained unchallenged until
27 December 14, 1995, when the California Supreme Court,
28 in Santa Clara County Transportation Authority v.
29 Guardino, 11 Cal. 4th 220 (hereafter Santa Clara) , as
30 modified on denial of rehearing, held that the voter
31 approval requirement of Proposition 62 for general taxes
32 did not violate the constitutional prohibition against a
33 referendum of a tax levy.
34 (f) Local governments could not reasonably have
35 foreseen that the Woodlake decision would be
36 disapproved by the California Supreme Court, in light of
37 the fact that the court repeatedly declined to address the
38 issue of Proposition 62's constitutionality.
39 (g) Consequently, it would be manifestly unfair and
40 unjust, and would cause severe economic hardship,
99
- 3 — SB 1590
)val 1 inequity, and disruption, to apply the decision in the
cal 2 Santa Clara case retroactively so as to threaten taxes
rnia 3 previously imposed by local governments in reasonable
The 4 reliance on existing law, as embodied in the Woodlake
the 5 and Rossi decisions.
n g 6 (h) Local governments throughout the state and the
7 recipients of the public services those agencies provide,
was 8 as well as parties to local government contracts and
the 9 holders of bonds and other debt instruments, are
nda 10 dependent upon uninterrupted funding from those taxes
3ral 11 potentially affected by the Santa Clara case for the
Y of 12 provision of essential public services, including police;
13 fire, and other public safety services.
the 14 (i) Public policy will be served by preventing the
,ase 15 disruptive and unjust effect of applying the Santa Clara
tax 16 case retroactively to threaten or impair taxes initially
.ent 17 imposed in reliance on the law at the time of the
of 18 Woodlake decision.
a of 19 (j) The retroactive application of the Santa Clara
20 decision to taxes previously imposed pursuant to the
in `} 21 Woodlake decision would require layoffs of public
ind 22 employees, including public safety officers, would
the 23 impede or require termination of many public projects,
.ing 24 threaten or eliminate matching fund programs with the
25 state and federal governments, and adversely affect the
ntil 26 state's economy.
urt, 27 (k) In Forster Shipbldg. Co. v. County of L.A., 54 Cal.
V. 28 2d 450, the California Supreme Court held that the
as 29 Legislature, as well as the courts, has the authority to
iter 30 apply California Supreme Court decisions, that overrule
Lxes 31 a prior statement of the law, prospectively only. It is the
A a 32 purpose of this act to limit the application of the Santa
33 . Clara decision by having it apply only to those tax
ave 34 ordinances and resolutions adopted after December 14,
be 35 1995, the date of the Santa Clara decision, after which
t of 36 there could no longer be justifiable reliance on the
the 37 Woodlake line of cases.
38 SEC. 2. Section 53716 is added to the Government
and 39 Code, to read:
1ip�
99 99
SB 1590 — 4 -
1
4 -
1 53716. (a) The decision of the California Supreme
2 Court in Santa Clara County Transportation Authority v.
3 Guardino, 11 Cal. 4th 220, as modified on denial of
4 rehearing, shall not be applicable to and shall not control
5 any action or proceeding in which the validity of a tax or
6 tax increase is contested, questioned, or otherwise in
7 issue, if the ordinance - or resolution imposing or
8 increasing, that tax was adopted prior to December 14,
9 1995.
10 (b) In no event shall any action or proceeding
11 contesting, questioning, or otherwise placing in issue the
12 validity of any portion of this section on any grounds be
13 filed any later than the 30th day after the effective date
14 of this section.
r
O
99
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