Manteca Unified School District v. Reclamation District No. 17
10 Cal. App. 5th 730
| Cal. Ct. App. | 2017Background
- Reclamation District No. 17 (Reclamation) levied annual assessments for flood control and levee projects within its boundaries; Manteca Unified School District (School) owns parcels in the district.
- Water Code §51200 (1951) authorizes reclamation districts to assess publicly owned lands but expressly excludes school districts from assessment.
- Proposition 218 (1996) added Cal. Const., art. XIII D, §4(a): publicly owned parcels are not exempt from assessments unless the public agency demonstrates by clear and convincing evidence the parcel receives no special benefit; art. XIII D §1 applies the article to all assessments notwithstanding other law.
- In 2008 Reclamation adopted an increased assessment via a Proposition 218-style ballot proceeding; School voted in favor and paid assessments for 2008–2011, then sued in 2011 seeking declaratory relief and reimbursement, arguing §51200 exempts it from assessment and Proposition 218 did not change that.
- The trial court held the assessments invalid under §51200 but denied School recovery of payments made during the litigation; it concluded Proposition 218 did not override §51200.
- The Court of Appeal reversed, holding art. XIII D §4(a) applies to preexisting statutory exemptions like §51200 and renders school property assessable unless the school shows by clear and convincing evidence it receives no special benefit.
Issues
| Issue | Plaintiff's Argument (School) | Defendant's Argument (Reclamation) | Held |
|---|---|---|---|
| Does Prop. 218 (Cal. Const., art. XIII D §4(a)) eliminate or limit the §51200 exemption for school property? | §51200 excludes school districts from assessment; Prop. 218 did not and cannot grant new authority to assess school property. | Prop. 218 conditions existing exemptions: school property is assessable unless the school proves by clear and convincing evidence it receives no special benefit. | Held: Art. XIII D §4(a) applies to §51200; school property is not automatically exempt and is assessable unless the school meets the clear-and-convincing no-benefit standard. |
| Does art. XIII D §1 ("notwithstanding any other provision of law") restrict application of §4(a)? | §1 does not override the specific carve-out in §51200; §51200 remains effective. | §1 makes art. XIII D apply to all assessments and supersedes conflicting statutory exemptions. | Held: §1 brings art. XIII D into effect over prior statutes; §4(a) conditions statutory exemptions like §51200. |
| Does applying §4(a) to §51200 amount to an unconstitutional implied repeal of §51200? | Applying §4(a) would repeal part of §51200 implicitly, which is improper absent express language. | §4(a) does not repeal §51200; it simply qualifies existing exemptions consistent with the Constitution. | Held: No impermissible implied repeal; §4(a) unambiguously conditions exemptions. |
| Was School entitled to reimbursement of assessments paid during the litigation? | School sought recovery of payments made. | Reclamation argued procedural defenses including statute of limitations. | Held: Court reversed trial judgment on substantive issue; resolution of reimbursement claim unnecessary (trial court erred in excluding Prop. 218 applicability). |
Key Cases Cited
- Silicon Valley Taxpayers' Assn., Inc. v. Santa Clara County Open Space Authority, 44 Cal.4th 431 (2008) (interpreting Proposition 218 and holding agencies bear burden to prove assessments valid)
- Reclamation District No. 684 v. East Bay Municipal Utility District, 91 Cal.App. 143 (1928) (early precedent on public-entity exemption from assessments)
- Barratt American, Inc. v. City of San Diego, 117 Cal.App.4th 809 (2004) (Proposition 218 does not impliedly repeal unrelated statutory limitations such as procedural statutes)
- International Engine Parts, Inc. v. Feddersen & Co., 9 Cal.4th 606 (1995) (de novo review of statute-of-limitations determinations)