American River Flood Control District v. Sayre

136 Cal. App. 3d 347, 186 Cal. Rptr. 202, 1982 Cal. App. LEXIS 2020
CourtCalifornia Court of Appeal
DecidedOctober 6, 1982
DocketDocket Nos. 20959, 20966
StatusPublished
Cited by5 cases

This text of 136 Cal. App. 3d 347 (American River Flood Control District v. Sayre) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American River Flood Control District v. Sayre, 136 Cal. App. 3d 347, 186 Cal. Rptr. 202, 1982 Cal. App. LEXIS 2020 (Cal. Ct. App. 1982).

Opinion

*350 Opinion

EVANS, Acting P. J.

These two petitions (consolidated for disposition) for writs of mandate arise out of Sacramento County’s (County) refusal to collect ad valorem special assessments on behalf of petitioners. For a number of years prior to July 1, 1978 (the effective date of art. XIII A of the Cal. Const.), 1 the County was required to and did collect special assessments utilized by petitioners for maintenance costs. The assessments were calculated as a percentage of the property values on the County’s ad valorem roll. Following adoption of article XIII A, the County has not kept an ad valorem roll, but rather a roll predicated upon acquisition values, not current cash value. The County has refused to collect petitioners’ ad valorem assessments, arguing the assessments as ordered would be invalid as they are not sufficiently proportional to benefits bestowed. We grant the petitions and order the County to collect as required by the pertinent statutes.

Background

In neither case is there a factual dispute.

The American River Flood Control District (District) is a state entity formed in 1927 under the American River Flood Control District Act (Stats. 1927, ch. 808, p. 1596, and amendments thereto, Deering’s Wat.—Uncod. Acts (1970 ed.) Act 320, p. 99; hereafter Act). Its function is to provide for control and disposition of storm and flood waters in a prescribed district along the American River. (Act, § 2.) This district has been divided into 11 “zones of benefit,” each zone bearing a percentage of the District’s maintenance costs proportional to the benefit each receives. (Act, § 8.)

Under section 18 of the Act, the District is authorized to levy assessments on land in the district in order to pay for operation and *351 maintenance. Section 17, subdivision (a), of the Act gives the District the option of collecting this assessment through the County of Sacramento. If the District chooses the County method, the county auditor is required to send the District a statement showing the total value of all land and improvements in the district, as well as the values in each zone. The values are to be ascertained from the County’s assessment book for the year the request is made. The District then fixes a rate of assessment for property in each zone sufficient to meet its estimated costs. These rates are transmitted to the County, which collects the assessment at the same time and in the same manner as county taxes.

As previously noted, for a number of years before July 1, 1978, the District had availed itself of this assessment collection means. Since that date, the County has treated the assessment as an ad valorem property tax, and only paid the District its share of the one percent tax collected under article XIII A, section l. 2

In 1980, following the decision in Solvang Mun. Improvement Dist. v. Board of Supervisors (1980) 112 Cal.App.3d 545 [169 Cal.Rptr. 391], petitioner District felt authorized to resume collection of an assessment based on a county ad valorem roll. It sent the county auditor notice of its intent to levy based on the County’s rolls, together with a table showing the rate of assessment in each zone. The County answered that it would not collect the assessments because in its opinion, the assessments would be in violation of article XIII A, section 1, subdivision (a), and void. The District filed this writ petition, noting it has nearly exhausted its reserves for maintenance.

The Department of Water Resources (Department) and the Reclamation Board (Board) are state agencies. Since the adoption in 1947 of *352 the provisions now contained in chapter 4.5 of Water Code, division 6, part 6 (Wat. Code, §§ 12878-12878.45), both Department and Board have had authority to delineate as “Maintenance areas” any areas found to be benefited by maintenance of a flood control project. (Wat. Code, § 12878, subd. (g).) Maintenance areas 9, 10 and 11, have been delineated along certain parts of the Sacramento and American Rivers; however no zones of benefit have been established within any area.

Each year the Department is required to estimate the cost of operation and maintenance of each project unit for the next fiscal year. '(§ 12878.27.) The estimates are fixed after notice and hearing (§§ 12878.28-12878.32); thereafter the Department must certify the amount required for each maintenance area to the county in which the area lies. (§ 12878.34.) The County is to levy an ad valorem assessment on the land within each maintenance area at a rate sufficient to raise the certified amounts. (§§ 12878.35, 12878.37.)

As in the case of the District, the County had levied and collected the-certified amounts until July 1, 1978. In 1981, the Department certified estimates for the 1981-1982 fiscal year. The County answered that it would not levy the assessments for the reasons previously noted.

Discussion

The question is whether the County must collect the requested assessments. We hold it must. We think it plain that the statutes (1) authorize both petitioners to levy special assessments, (2) require the County to collect those assessments, and (3) require it to collect based on an ad valorem tax roll, or in the alternative to levy a special benefit assessment. Further, the adoption of California Constitution, article XIII A, does nothing to change this obligation of the County.

In Solvang Mun. Improvement Dist. v. Board of Supervisors, supra, 112 Cal.App.3d 545, the court articulately defined the characteristics of a special assessment: “. . . a special assessment, sometimes *353 described as a local assessment, is a charge imposed on particular real property for a local public improvement of direct benefit to that property, as for example a street improvement, lighting improvement, irrigation improvement, sewer connection, drainage improvement, or flood control improvement. The rationale of special assessment is that the assessed property has received a special benefit over and above that received by the general public. The general public should not be required to pay for special benefits for the few, and the few specially benefited should not be subsidized by the general public. (Burnett v. Mayor etc. of Sacramento (1859) 12 Cal. 76, 83-84.) The theory underlying special assessment is that the local improvement, such as the paving or lighting of a street, directly benefits and increases the value of adjacent real property. . . . Although a special assessment is imposed through the same mechanism used to finance the cost of local government, in reality it is a compulsory charge to recoup the cost of a public improvement made for the special benefit of particular property... [11] ... In sum, a special assessment is a charge levied against real property particularly and directly benefited by a local improvement in order to pay the cost of that improvement. ...” (Pp. 552-554.)

The statutes in question call for just such an assessment.

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Bluebook (online)
136 Cal. App. 3d 347, 186 Cal. Rptr. 202, 1982 Cal. App. LEXIS 2020, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-river-flood-control-district-v-sayre-calctapp-1982.