City and County of San Francisco v. Farrell

KAUS, J., Dissenting.

As the various opinions in this case make clear, the terms of Proposition 13 itself provide no hint of what the drafters of the initiative had in mind when they used the term “special taxes” in article XIII A, section 4. As I noted in my separate opinion in Los Angeles County Transportation Com. v. Richmond (1982) 31 Cal.3d 197, 208-209 [182 Cal.Rptr. 324, 643 P.2d 941], however, “the description and discussion of [section 4] in the election pamphlet which was before the voters suggest to me that the purpose of this section was simply to limit the authority of a city, county or special district to impose new ‘special taxes’ to replace property tax revenue that the city, county or special district lost as a result of the other portions of Proposition 13.” (Orig. italics.)

If section 4 was indeed intended to restrict the ability of local entities to replace the property tax losses mandated by Proposition 13, then the interpretation of “special taxes” adopted by the court is clearly off the mark. As construed by the majority, section 4 places no limit whatsoever on the ability of local entities to levy the traditional, run-of-the-mill revenue-raising taxes for general municipal purposes, but—quite perversely—only makes it more difficult for such entities to levy much more unusual and more limited “special purpose” taxes. Since I can think of no plausible reason for the drafters to have intended such an irrational and ineffectual scheme, I must respectfully dissent.

*59In my view, section 4 will serve its apparent intended purpose only if the phrase “special taxes” is read to mean “new,” “additional,” or “supplemental” taxes which are enacted to replace tax revenue lost as a result of Proposition 13’s limitations on the property tax. Contrary to the majority’s suggestion, I do not believe that this interpretation reads the word “special” out of section 4 altogether. If the word “special” were completely eliminated, section 4 could be read to require a two-thirds vote of the electorate to authorize any tax levied by local entities after July 1, 1978, including the mere continuation of local taxes that were already in place before the adoption of Proposition 13. The inclusion of the modifier “special” in section 4 was intended to make it clear that local entities are permitted to maintain their pre-Proposition 13 nonproperty taxes without a two-thirds voter approval; only “new” or “additional”—i.e., “special”—taxes, which would inevitably replace the property tax revenue withheld by other portions of Proposition 13, are subject to the two-thirds requirement.

In sum, given the purpose of the provision, I conclude that the tax in question is a “special tax” within the meaning of section 4 of article XIII A. Accordingly, I would deny the requested writ.

Respondent’s petition for a rehearing was denied September 30, 1982. Richardson, J., and Kaus, J., were of the opinion that the petition should be granted.