Howard Jarvis Taxpayers Assn. v. City of L.A.

CourtCalifornia Court of Appeal
DecidedDecember 15, 2025
DocketB334071
StatusPublished

This text of Howard Jarvis Taxpayers Assn. v. City of L.A. (Howard Jarvis Taxpayers Assn. v. City of L.A.) 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
Howard Jarvis Taxpayers Assn. v. City of L.A., (Cal. Ct. App. 2025).

Opinion

Filed 12/15/25 CERTIFIED FOR PARTIAL PUBLICATION */

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION FOUR

HOWARD JARVIS TAXPAYERS B334071 ASSOCIATION, et al., (Los Angeles County Plaintiffs and Appellants, Super. Ct. Nos. v. 22STCV39662, 23STCV00352) CITY OF LOS ANGELES, et al.

Defendants and Respondents.

APPEAL from an order of the Superior Court of Los Angeles County, Barbara M. Scheper, Judge. Affirmed. Howard Jarvis Taxpayers Foundation, Jonathan M. Coupal, Timothy A. Bittle, Laura E. Dougherty, and Amy C. Sparrow for Plaintiffs and Appellants Howard Jarvis Taxpayers Association and Apartment Association of Greater Los Angeles. Law Offices of Keith M. Fromm, Keith M. Fromm for Plaintiff and Appellant Jonathan Benabou, as Trustee on Behalf of the Mani Benabou Family Trust.

Pursuant to California Rules of Court, rules 8.1100 and *

8.1110, this opinion is certified for publication with the exception of part II of the Discussion. Bell, McAndrews & Hiltachk, Thomas W. Hiltachk, Brian T. Hildreth, Katherine C. Jenkins, and Logan W. Bambino for California Association of Realtors as Amicus Curiae on behalf of Appellant Howard Jarvis Taxpayers Association. Burke, Williams, & Sorensen, Kevin D. Siegel, J. Leah Castella, and Eileen L. Ollivier for Defendant and Respondent City of Los Angeles. Collins + Collins, Brian K. Stewart and Nicholas R. Colletti for Defendants and Respondents County of Los Angeles and County of Los Angeles Recorder’s Office. Irell & Manella, Morgan Chu, Michael Ermer, Charlotte J. Wen, Connor He-Schaefer, Nick Wagner, Woongki Park, and Taylor A. Hatridge; Public Counsel, Gregory Bonett, Faizah Malik, and Jonathan Jager for Defendants and Respondents Southern California Association of Non-Profit Housing, Inc., Korean Immigrant Workers Advocates of Southern California dba Koreatown Immigrant Workers Alliance, and Service Employees International Union Local 2015.

2 Under the California Constitution, the people retain the power to enact special real property transaction taxes by local initiative. (Cal. Const., art. II, §§ 1, 11; art. IV, § 1.) The main issue in this case is whether the people revoked this power when they adopted section 450(a) of the Los Angeles City Charter (section 450(a).) We hold that the people did not do so. In the November 2022 General Municipal Election, voters in the City of Los Angeles approved “Initiative Ordinance ULA” (Measure ULA). Measure ULA authorizes an additional tax on the sale or transfer of real property exceeding $5 million. The revenue from the special transaction tax 1 is allocated to various housing and homelessness-related programs administered by the Los Angeles Housing Department. Plaintiffs and appellants Howard Jarvis Taxpayers Association and Apartment Association of Greater Los Angeles (collectively, Howard Jarvis), and Jonathan Benabou, Trustee of the Mani Benabou Family Trust (Benabou) appeal from the trial court’s order dismissing their complaints alleging that Measure ULA is invalid. Howard Jarvis principally contends that Measure ULA is invalid because it conflicts with section 450(a). Section 450(a) provides, in part, that “[a]ny proposed ordinance which the Council itself might adopt may be submitted to the Council . . . requesting that the ordinance be adopted by the Council or be submitted to a vote of the electors of the City.” (Italics added.) It is undisputed that charter cities may impose general transaction taxes, but under article XIII A, section 4 of

1 A special tax is a tax imposed for a specific purpose. (City and County of San Francisco v. Farrell (1982) 32 Cal.3d 47, 58; Cal. Const., art. XIII C, § 1, subdivision (d).)

3 the state Constitution (section 4), they are prohibited from imposing real property special transaction taxes such as Measure ULA.2 (See Fielder v. City of Los Angeles (1993) 14 Cal.App.4th 137, 142 (Fielder).) Relying on the italicized language in section 450(a), Howard Jarvis argues that because the City Council could not itself have enacted Measure ULA, voters cannot enact Measure ULA either. In the published portion of this opinion, we conclude the passage of Measure ULA pursuant to a majority vote of the City’s electorate was a valid exercise of the people’s initiative power. While section 4 restricts a local government’s ability to impose a special transaction tax, it does not limit the ability of voters to do so via initiative. (City and County of San Francisco v. All Persons Interested in the Matter of Proposition C (2020) 51 Cal.App.5th 703, 721 (Proposition C).) Howard Jarvis attempts to circumvent section 4’s limited scope by arguing that section 450(a) revokes the people’s reserved initiative power with respect to special transaction taxes. We reject this argument. When read in context and through the lens of well-established principles interpreting the people’s power of initiative, section 450(a) does not invalidate Measure ULA. In the unpublished portion of this opinion, we address Benabou’s challenges to Measure ULA on constitutional grounds, including that it violates the Fourteenth Amendment’s Equal Protection Clause and the First Amendment, and various other

2 Section 4 provides: “Cities, Counties and special districts, by a two-thirds vote of the qualified electors of such district, may impose special taxes on such district, except ad valorem taxes on real property or a transaction tax or sales tax on the sale of real property within such City, County or special district.”

4 grounds including alleged misrepresentations in the ballot materials, preemption, and purported factual issues that preclude judgment on the pleadings. We conclude that none of Benabou’s contentions has merit.

BACKGROUND

Measure ULA was proposed on May 2, 2022, through the voter initiative procedure in Los Angeles. It was placed on the ballot at the General Municipal Election on November 8, 2022, where it passed with 57.77% of the vote. On December 21, 2022, Howard Jarvis filed a reverse validation action against the City of Los Angeles (the City) pursuant to the validation statutes (see Gov, Code, § 50077.5; Code Civ. Proc., §§ 860-870.5) challenging Measure ULA under the Los Angeles City Charter and section 4. Benabou filed a separate reverse validation action against the City, the County of Los Angeles, and the County of Los Angeles Recorder’s Office, challenging Measure ULA under 16 additional causes of action. The court consolidated the two cases. The City answered both complaints, defending the validity of Measure ULA. Southern California of Association of Non- Profit Housing, Inc., Korean Immigrant Workers Advocates of Southern California dba Koreatown Immigrant Workers Alliance, and Service Employees International Union Local 2015, on behalf of All Persons Interested in the Matter of Measure ULA, also answered the complaints. The parties filed cross-motions for judgment on the pleadings. After a hearing on the motions, the trial court granted judgment on the pleadings in favor of defendants, and entered an order of dismissal. Howard Jarvis and Benabou appeal from the dismissal order.

5 DISCUSSION

I. Neither Section 450(a) Nor Section 4 Revoke the People’s Initiative Power with Respect to Special Real Property Transaction Taxes The people’s initiative power is both statewide and local. (Cal. Const., art. II, §§ 8, 11.) Charter cities such as Los Angeles regulate their own initiative procedures. (San Diego Public Library Foundation v. Fuentes (2025) 111 Cal.App.5th 711, 722, citing Cal. Const., art. XI, §§ 2, 3, & 5, subd. (a).) The California Constitution speaks of the initiative power not as a right granted to the people, but as a power “the people reserve to themselves.” (Cal. Const., art. IV, § 1; see Dwyer v. City Council of Berkely (1927) 200 Cal.

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Howard Jarvis Taxpayers Assn. v. City of L.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-jarvis-taxpayers-assn-v-city-of-la-calctapp-2025.