HomeMy WebLinkAboutAgenda Report - January 17, 1990 (51)COUNCIL COMMUNICATION
TO: THE CITY COUNCIL COUNCIL MEETING DATE
FROM: THIE CITY MANAGER'S OFFICE JANUARY 17, 1990
SUBJECT: CHALLENGE TO PROPERTY TAX ALLOCATION METHOD
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PREPARED BY: City Attorney
RECOMMENDED ACTION: Council consideration of the attached request firom
the California Contract Cities Association, seeking
$250.00 for legal fees in a challenge to the
statutory apportionment method for property taxes.
DISCUSSION: Last month, a request was received from .the
California Conteaet Cities Association (CCCA) for
assistance with legal fees in a challenge to SB154
and AB8 (generall codified in Revenue and Taxation
Code §§95 - 100. The basis of the legal action
(outlined in more detail in the attachments hereto) is that these two pieces
of legislation. passed to implement Proposition 13, violate the "tax situs"
provision of the California Constitution.
If the CCCA's position is correct, the County would be required to calculate
the apportionment of property taxes on a different basis. This could increase
Lodi's share by an estimated $163,879.00 per year, under the CCCA's
projections. However, I am not certain of tthe realiability of that a5timate.
CCCA has calculated a prorated schedule er proposed contribution for cities,
with Lodi's suggested assessment being $250.00. It is my understanding that
we would not be named as a litigant in the actual lawsuit, which has already
been filed. The City's posture would be more in the nature of amicus curiae.
It should be remembered that the suit d1rectly involves only th? cities of
CCCA and the Counties of Sar, Bernardino, Los Angeles, and Riverside. Even if
the action is successful, it could still require further effort to implement
it locally.
It is my belief that the potential benefits justify the $250.00 in legal fees
sought by the CCCA.
Respectfully submitted,
BOB McNATT
City Attorney
BM:vc
PROPTAX.CC/TXTA.OIV
MEMORANDUM
To: Honorable Mayor Randy Snider
From: Bob McNatt, City Attorney
Date: December 18, 1989
Subj: Property Tax Allocation Lawsuit
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I read with interest the letter of December 1, 1989 from the California
Contract Cities Association regarding its challenge to the method of
property tax allocatior: under SB154 and AB8. It may be to Lodi's benefit
to look further into this lawsuit.
Since I have no special expertise in taxation law, I called Joanne
Speers, an attorney with the League of California Cities. The League is
aware of the suit which was filed in April of this year against the
counties of Los Angeles, San Bernardino, and Riverside. Joanne said the
Legal Advocacy Committee of the League has not taken a position, since the
suit could pit some cities against others in competition for tax dollars.
The whole issue apparently involves the "tax situs" provisions of
California Constitution Article 13, Section 14, which simply says:
"All property taxed by local government shall be assessed in
the county, city and district in which it is situated."
As I understand it, SB154 and AB8 established apportionment rules
to distribute the taxes collected under Proposition 13, by reference to
the amount of property taxes collected before Proposition 13 was
adopted. The suit alleges that changes in the "tax rate areas" since
then have resulted in some cases in prcperty taxes being transferred
across jurisdictional boundaries within a county. This occurred where
the tax rate areas' share of county -wide assessed valuation was more or
less than its "historic" share (than is, prior to Proposition 13). In
essence, the lawsuit says that SB154 and AB8, which allow property
tax dollars to move across these jurisdictional boundaries within a
county, violates Article 13, Section 14 of the Constitution.
The Association's two-step proposal results in the County governments
receiving the same share of property taxes, but then allocates to each
city and special district within the county, only the amount of
property taxes paid by taxpayers within the boundaries. I must admit
that this sounds to me consistent with the plain language of Article
13, Section 14 of the Constitution.
Memorandum
Mayor Randy Snider
December 18, 1989
Page Two
In looking at the table on page 15 of the Association's document, it
projects a gain to Lodi of $163,879 in property taxes if the allocation
method urged by theAssociationwas used. Of course, this. increase
would result in, certain decreases to the cities of.,Stockton and Tracy.
The League would not speculate on the_suii's chance of success, but
also would not say*hat the Association's position was without some
justification. It looks to me like the possible benefits might justify
the rather modest $250 requested as Lodi's share of legal fees.
I will be happy to look further into this matter if desired.
t
Bob McNatt
City Attorney
BM: VC
cc: City Council Members
City Manager
PROPTAX/TXTA.01V
California
Contract Cities :
Association
3380 Flair Drive, Suite #217 • EI Monte, California 91731-2825 • (818) 288.4444
.0
PRESIDENT
ALBERT G. PEREZ
South EI Monte
1st VICE PRESIDENT
JUDY HATHAWAY
La Habra Heigh%
2nd VICE PRFSIDENT
MARY LOU SWAIN
Temple City
SECRETARY
GILBERT DE LA ROSA
Pico Rivera
TREASURER
TOM THURMAN
Cudahy
PAST PRESIDENT
MARCIAL "Rod" RODRIGUEZ
Norwalk
EXECUTTvw. BOARD
CHARLES BELGA
Lomita
KEN CLEVELAND
Be110ower
BELL CUNNINGHAM
Huntington Park-
TOM
arkTOM JACKSON
Huntington Park
ART LESLIE
La Mirada
CURTIS MORRIS
San Dimas
ART NAVARRO
Commerce
CHARLES RICHARDSON
Walnut
JIM VAN HORN
Artesia
SAN DIEGO CHAPTER CHAIRMAN
GLORIA McCLELLAN
EXECUTIVE DIRECTOR
SAM OLIVITO
December 1, 1989
Dear Mayor & City Council,
The California Contract Cities Association
wishes to inform you of a lawsuit filed on behalf cf
a group of cities challenging the Constitutionality
of the State's method of allocating property tax
revenues among California -cities since passage of
Propostion 13 in 1978. While Proposition 13 is not
the focus of the Constitutional challenge, the
implementing legislation SB154 and AB8, which set the
formula for allocation of tax revenues under
Proposition 13 limitations is the basis for the
lawsuit, which declares that the property taxes
collected under the 1% tax limit has been apportioned
In a way that violates tax sites and tax uniformity
according to Section 14 and Section 1 of Article %III
of the California Constitution.
The Association sponsored and financed a study and
extensive research into the constitutional questions
posed, including the basis for and history of
property tax measures. The study was conducted by
the Claremont McKenna College Center For Study of
Public Law. This research,.and a subsequent analysis
of property tax allocations and distribution by the
firm of Stratecon, Inc., form the basis of the legal
action.
It is not the intent nor purpose of the law suit to
attack Proposition 13. Rather, it challenges the
unconstitutional implementation legislation
formulated by the California Legislature under which
tax revenues are now distributed, the California
Legislature's implementation of Proposition 13
needlessly shattered the constitutional principles of
tax situs and uniformity.
Section 14 (of Article XIII of the California
Constitution) contains the tax situs requirements of
the California Constitution which prr�vide that the
benefits of taxation should be directly received by
those who bear the burden of taxation. Also, the
current legislative formula for allocation of tax
revenues "violates the tax situs requirement of
Article VIII, Section 14 of the California
Constitution in that the direct benefit from the tax
'Page, 2
imposed on real property situated within the cities is not inuring to the
taxpayers, but rather to real property located across jurisdictional
line. in cities that have levied a high property tax in the 1977-78
fiscal year.
The legal action was filed on behalf of five cities by Attorney John
Sturgeon and other attorney members of the law firm of Sheppard, Mullin,
Richter &Hampton. The five are Rancho Cucamonga, Temple City, Compton,
E1 Segundo and Carson.
The Contract Cities approved assessments on themselves to cover the
cost of these studies, and the legal action. They have been joined in
the suit by the City of E1 Segundo, a non-member now named a-- one of the
five petitioning cities. Because you are a city which will receive
property taxes now being lost to other jurisdictions by this
unconstitutional formula, your city is being invited to join the suit and
help finance the action with assessments similar to those paid by the
Contract Cities and -the City of E1 Segundo.
Attached is the Executire Summary which is a part of the points and
authorities of the lawsuit. Also attached is a sheet showing property
taxes allocated under existing law for 1987-88 and what would be the gain
under the simple remedy to your city. We have also included an
assessment far the legal work already in progress and anticipated future
legal costs which could be as much as $500,000. Based upon the
percentage of gain in property taxes the assesment for legal fees for
your city is $250.00
If you need any further information or assistance, please contact
our Executive Director Sam Olivito at (818) 288-4444.
z
I. INTRODUCTION: POST -PROPOSITION 13
APPORTIONMENT OF PROPERTY TAXES
The legislative implementation of Proposition 13 violates Section 14 (tax si-
tus) and Section 1(tax uraformity) of Article XIII of the California Constitution. As
a result, taxpayers living in jurisdictions with low -tax rates and high-growth before
Proposition 113 now pay property taxes that are apportioned, in part, to local gov-
ernments that do not serve them. These revenue transfers are fiscally significant
and will grow over time. The problem is of statewide significance because every
property tax dollar collected under the 1% tax limit has been apportioned in a way
that violates tax situs and tax uniformity. The problem can be. remedied, however,
by suitable modification of the Revenue & Tax Code.
This study has three objectives: 1) to explain. the problems with existing law;
2) to estimate the magnitude of the revenue transfers for taxpayers of selected cities
in Sar, Bernardino County and Los Angeles County; and 3) to demonstrate how
property taxes can be apportioned while satisfying tax situs and tax uniformity. The
major conclusions are summarized below.
A. THE PROBLEM -S WITH EXISTING LAW
The problems with existing law can be demonstrated by comparing the prop-
erty tax system before and after Proposition 13.
Before Proposition 13, tax situs and tax uniformity were the pillars of prop-
erty taxation in California. Each local government decided their property tax rate,
subject to a statutory maximum.' They submitted these rates to the county auditor
who then computed the total property tax levied on each property in the .county.
The county tax collector collected all property taxes and remitted the proceeds to
' See West's Ann.Cal.Rev. & T. Code, Section 2260 et seg.
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local governments in accordance with the tax rates stated on taxpayer bills.2 There-
fore, taxpayers paid only the tax rates levied by the local governments that served
them. Their local governments, in turn, only received property taxes from taxpayers
within their Jurisdictional boundaries. That is, the assessment of property taxes sat-
isfied tar situs. Moreover, taxpayers paid uniform property tax rates because each of
their local governments levied an uniform tax rate. That is, property taxation satis-
fied the tax uniformity requirement of the California Constitution.
Proposition 13 placed a 1% limit on the taW property tax rate paid by a tax-
payer, subject to an override for debt service. It also rolled back FY 1978-79 taxable
assessed valuations and limited subsequent growth in those valuations s It did not,
however, describe how the revenues collected under these limits were to be dis-
tributed; it only required that revenues "be apportioned according to law." 4 To im-
plement Proposition 13, the Legislature passed SB 154 to apportion Property taxes
for FY 1978-79. One year later it passed AB 8, which has apportioned property tax
revenues for every subsequent fiscal year.
This legislation, as amended, defines the formula used by county auditors to
apportion countywide property tax revenues among local governments.s In FY
1986-87, for example, cities were allocated 13 percent of countywide property tax
revenues, county governments 33 percent, schools 36 percent, and special districts
18 percent 6 The division of the city share arnong cities, the school share among
See West's Ann.Cal.Rev. cot. T. Code, Section 2601 et seq.
3 Cal.Const. Article X11IA, Sections 1(a), 2.
4 Id, Section 1(a).
5 See West's A.nn.Cal.Rev. & T. Code, Section 95 through 100.
6 See California State Board of Equalization, Annual Report 1986-87, Table 15, p. A-
19. This data includes property tax revenues collected under the 10/0 lifnit as well as
debt levies. Therefore, the percentages in the text only approximate the allocation
of 1% property tax revenues, though the error from the inclusion of debt levies is
minor. The average statewide property tax rate (inclusive of debt levies) in FY
3
schools, and the special district sliare among special districts was tied to the amount
of property tax revenues collected by each local government before Proposition 13.
To understand why this apportionment of property tax re-jenues violates tax situs
and tax uniformity, consider the specific provisions of existing law.
SB 154 apportioned FY 1978-79 countywide property tax revenues among 10 -
cal governments in proportion to each government's historical collection of property
taxes.? While each taxpayer contributed 1% of his assessed valuation into the;pool
of countywide property tax revenuesa the revenues received by the governments
that serve him depend on pre -Proposition 13 assessed'valuation anti pre -Proposition
13 tax rates. Within a given tax rate area,9 taxpayers paid more, or less, in property
taxes than revenues received by their local governments, depending on whether the
tax rate area's share of countywide taxable assessed valuation was greater, or less,
than its local governments' historical share of countywide property tax revenues.
SB 154 transferred property tax monies across jurisdictional boundaries. Tax
rate areas with low -tax rates and high-growth rates before Proposition 13 received 0
smaller revenue allocations than their residents paid in property taxes for two rea-
sons: (1) their share of historical countywide property taxes was less than their share
of historical countywide assessed valuation, and (2) their historical share of county-
wide taxable assessed valuation was less than, their current share of taxable assessed
valuation. In contrast, tax rate areas with high -tax rates and low -growth before
1986-87 was 1.083 percent (Id, Table 14, p. A-18), suggesting that debt service was
only 8.3 percent the magnitude of property tax revenues raised under the 1% limit.
7 See Appendix A, infra.
R Until 1982, the property tax limit was 4% because assessed value- were expressed
as 25 percent of full values. Thereafter, assessed values have been stated in terms of
lav percent of full values. For purposes of continuity, the discussion in Section I
uses the contemporary value of the tax limit.
9 A tax rate area is "a specific geographic area all of which is within the Jurisdiction
of the same combination of local agencies and school entities". See West's
Ann.Cal.Rev. & T. Code, Section 95(g).
4
Proposition 13 received greater revenue allocations than their residents paid in
property taxes. SB 154 violated tax situs.
In 1979, the Legislature Passed AB 8 --complex in practice but simple in con-
cept 10 Each local government received a property tax allocation equal to a base al-
location plus a share of the growth in the property taxes paid by taxpayers in tax rate
are.as within its boundaries. AB 8 defined base allocations to be the property tax
allocations received under SB 154.11 The growth in property tax revenues generated
within each tax rate area was allocated among local governments serving residents
in that tax rate area in proportion to the base allocations each local government had
received from that tax rate area.12
AB 8, therefore, perpetuated the tax situs problem of SB 154 and violated tax
uniformity. It violated tax situs by using the revenue allocations under SB 154 to de-
fine base allocations for local governments. Because the Legislature allocated the
growth in property tax revenues paid by taxpayers to governments that served them,
the magnitude of the tax situs problem did not grow. However, taxpayers who suf-
fered.from the violation of tax situs were further disadvantaged by the method that
allocated the growth in property tax revenues. Because the revenue allocations to
their cities, schools, and special districts were relatively low, county government was
allocated a relatively high share of the growth in their property taxes. The situation
was the opposite for taxpayers whe benefited from the violation of tax situs. Be-
cause the revenue allocations of their cities, schools, and special districts were high,
the same county government was allocated a relatively low share of the growth in
to See Appendix A, infra.
11 AB 8 also redefined the property tax allocation received under SB 254. See
Appendix A, infra. This redefinition of SB 154 allocations intensified the violation
of tax situs. See Section 11, infra.
12 AB 8 first attributed base allocations of local governments among tax rate areas,
and then used mese attributed revenues to al�portidn the growth of property tax
revenues among local governments. See Appendix A, infra.
their property taxes. Depending on which tax rate area they lived within the county,
taxpayers paid different rates to the county government. AB 8 violated tax urdfo:-
mity.
B. THE EFI`EEMS ON TAXPAYERS IN SAN BERNARDINO COUNTY AND LOS
ANGELES COUNTY
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Sub -section deleted
3
6
C- PROPOSITION 13 CAN BE IMPLEMENTED WITHOUT VIOLATING TAX
SITUS AND TAX UNIFORMITY
Property tax revenues can be apportioned without violating tar situs and tax
uniformity if existing law is modified to use a two-step procedure:
1) divide countywide collections of the 1% Property tax among differ-
ent open of Local governments --county, cities, types of school dis-
tricts, types *of special districts (eg. flood, fire, sanitation, water,
etc. );
2) within each category of local government, apportion revenues on
the basis of the taxable assessed valuation of local governments.
The first step assures that county government receives the same share of each tax-
payer's property taxes; that is, it guarantees that the apportionment of property
taxes satisfies tax uniformity. The second step assures that each local government
only receives the amount of property taxes paid by taxpayers within their bound-
7
ages; that is, it guarantees teat the apportionment of property tax revenues satisfies
tat; situs.
This remedy limits, but dotes no., eliminate, the role of the Legislature in
deciding how property tax revenues should be apportioned. The Legislature must
decide how to divide countywide property taxes arong different types of local gov-
ernments. If it wished, the Legislature can use the provisions of existing law. If it
decides to amend existing law, the Legislature must treat all cities, or all school dis-
tricts of a particular type, or all special districts of a particular type on an equal ba-
sis.
The second step of the allocation could be implemented in two ways. The
simple remedy would divide revenues without regard to. whether all tax rate areas are
sewed by all types of local government. The thorough remedy would use a
credit/debit scheme in which a city's allocation from the simple remedy would be
increased if it provided services which residents in other cities received from special
districts, or a city's allocation would be reduced if its residents received services
from special districts that were offered by full lines -of -service cities.
The choice between the simple and thorough remedy depends on the degree
of precision desired by the California Supreme Court. If it desires to correct consti-
tutional violations to the :very last penny," the Court should embrace the thorough
remedy. If the Court would be content with substantial compliance with constitu-
tional principles, the simple remedy will do.
The problems with existing law are of statewide significance. In FY 1984-85,
for example, implementation of the simple remedy would have affected the alloca-
tion of 17.8 percent of the $1.1 billion of city property tax revenues apportioned
statewide.1-3 Two hundred and fifty -t
13 See Section IV.
cities, with almost 8 million residents,
would have b, --en allocated more revenues, and one hundred and seventy-four cities,
14
with almost 11 million residents, would have been allocated less revenueL
The argument is developed in three sections. Section II analyzes the appor-
tionment of property tax revenues in a hypothetical:,county to explain why existing
law violates tax situs and tax uniformity. Section III describes the methodology, data
sources, and findings from case studies of the apportionment of property tax rev-
enues among local governments in San Bernardino County and Los Angeles County.
Section IV explains how exist n law e� Ln be reformed xP ' g U', implement Proposition 13
while conforming with tax situs and tax uniformity.
14 Id.
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