Pacific Bell Telephone Co. v. County of Ventura

CourtCalifornia Court of Appeal
DecidedSeptember 25, 2025
DocketB337518
StatusPublished

This text of Pacific Bell Telephone Co. v. County of Ventura (Pacific Bell Telephone Co. v. County of Ventura) 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
Pacific Bell Telephone Co. v. County of Ventura, (Cal. Ct. App. 2025).

Opinion

Filed 9/25/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SIX

PACIFIC BELL TELEPHONE 2d Civ. No. B337518 COMPANY et al., (Super. Ct. No. 2023CUMC015383) Plaintiffs and Appellants, (Ventura County)

v.

COUNTY OF VENTURA et al.,

Defendants and Respondents.

Appellants Pacific Bell Telephone Company, AT&T Mobility LLC, AT&T Corp., Sprint Communications Company, L.P., Sprint Spectrum, L.P., T-Mobile West LLC, and CenturyLink Communications, LLC (collectively Appellants) are utility companies operating in the State of California, including the County of Ventura (the County). Appellants sued the County and the Board of Equalization (the Board) 1 seeking a partial

1 The Board is a defendant in the lawsuit pursuant to Revenue and Taxation Code section 5146, but no cause of action refund on property taxes because they were taxed at a higher rate than other nonutility property (common property). They contend that an alleged property tax rate disparity violates section 19 of article XIII of the California Constitution (article XIII, section 19). The trial court sustained the County’s demurrer. We do not write on a blank slate. Several of our colleagues in districts across the state have decided the same issue against Appellants. (County of Santa Clara v. Superior Court (2023) 87 Cal.App.5th 347 (Santa Clara); Pacific Bell Telephone Co. v. County of Merced (2025) 109 Cal.App.5th 844 (Merced); Pacific Bell Telephone Co. v. County of Placer (2025) 111 Cal.App.5th 634 (Placer); Pacific Bell Telephone Co. v. County of Napa (2025) 112 Cal.App.5th 952 (Napa).) We agree with these courts and affirm. FACTUAL AND PROCEDURAL HISTORY 2 Both utility and common property are subject to “ad valorem” property taxes, which are taxes imposed based on

was alleged against it.

2 Appellants requested judicial notice of 30 exhibits, including materials related to the legislative history for article XIII, section 19, legislative documents related to Revenue and Taxation Code section 100, materials relating to article XIII, section 1 of the California Constitution, ballot materials relating to Proposition 13, briefs and other documents in other cases, and excerpts from dictionaries. We grant judicial notice of Appellant’s first request for judicial notice of exhibits 1–14 and 21–22. We also grant Appellants’ second request for judicial notice of exhibits 1, 2, 5, 7, and 8. We deny judicial notice of the other exhibits because they are not relevant or necessary to our resolution of this appeal. (San Diego City Firefighters, Local 145 v. Bd. of Admin. of San Diego City Emples. Ret. Sys. (2012) 206

2 assessed property value. (Merced, supra, 109 Cal.App.5th at p. 850, fn. 1.) Most common property, including real property, is locally assessed and taxed. In contrast, utility property is “[s]tate-assessed” by the Board under the principle of unit valuation that requires determining the value of the property as a whole, rather than the value of its individual assets. (See Rev. & Tax. Code, 3 §§ 108, 723; ITT World Communications, Inc. v. City and County of San Francisco (1985) 37 Cal.3d 859, 863 (ITT).) The Board allocates the assessed value to individual counties. The counties then apply a tax rate to the assessed value. (ITT, at p. 864; §§ 755–756.) There are two components to property tax rates: (1) a tax of 1% of the full cash value to fund county services, and (2) a debt service component. (Cal. Const., art. XIII A, § 1; §§ 93, 100.) The debt service component for common property is based on the amount needed to pay for the interest and principal on all voter-approved “bonded indebtedness” in the tax rate area in which the property is located. (§ 93, subd. (c).) Common property

Cal.App.4th 594, 600, fn. 3.) The County also requested judicial notice of three volumes of exhibits (exhibits A–C) including legislative materials relating to article XIII, section 19 and Revenue and Taxation Code section 100. We grant judicial notice of the County’s exhibits A–C. We have previously granted motions to file amici curiae briefs, including one submitted by the California Taxpayers Association. However, we will not consider the Declaration of William G. Hamm, Ph.D., which was not presented to the trial court. (See City of Petaluma v. Cohen (2015) 238 Cal.App.4th 1430, 1438, fn. 7.)

3 Further unspecified statutory references are to the Revenue and Taxation Code.

3 is assigned to a “tax rate area” within the county. 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 for the current fiscal year.” ’ [Citation.]” (Santa Clara, supra, 87 Cal.App.5th at p. 362.) A county may have hundreds or thousands of tax rate areas. (BNSF Railway Co. v. County of Alameda (9th Cir. 2021) 7 F.4th 874, 881–882 (BNSF).) Unitary property, including utilities, however, is assigned to one countywide tax rate area. (§ 100, subd. (a).) Section 100, subdivision (b) sets forth the formula for calculating the debt service tax rate of unitary property. Unlike common property, the debt service component for unitary property is “ ‘based on the change in absolute dollars of the county’s debt service rate.’ ” (Placer, supra, 111 Cal.App.5th at p. 642.) The difference in the way the debt service component for common and unitary property is calculated can result in disparate debt service rates. Appellants sued the County and the Board in Ventura Superior Court under sections 5140 and 5096 et seq., seeking property tax refunds for the fiscal years between 2018 and 2023. Appellants contended the property tax rate for utility property was set at a “discriminatory” rate “in excess of the average property tax rate” for common property in contravention of article XIII, section 19. That section provides in relevant part: “The Board shall annually assess . . . property, . . . owned or used by regulated railway, telegraph, or telephone companies, car companies operating on railways in the State, and companies transmitting or selling gas or electricity. This property shall be subject to taxation to the same extent and in the same manner as other property.” (Cal. Const., art. XIII, § 19.) The County demurred, contending that Santa Clara, supra, 87 Cal.App.5th

4 347 was binding precedent and required dismissal. The parties stipulated that Santa Clara was binding precedent and consented to judgment in favor of the respondents for the purpose of facilitating this appeal. (Norgart v. Upjohn Co. (1999) 21 Cal.4th 383, 400.) Pursuant to the stipulation, the trial court sustained the demurrer and entered judgment in favor of the County and the Board. DISCUSSION Unit taxation in California From 1910 into the 1930’s, public utility property was subject to a “special gross receipts ‘in lieu’ tax” levied and collected by the state while common property was subject to regular ad valorem property taxes levied and collected by local government. (ITT, supra, 37 Cal.3d at p. 862.) By the early 1930’s the Great Depression brought about a crisis in taxation. “Local tax rates were believed to be too high, in part because public utility property was not on the local tax rolls; state revenues were believed to be too low, in part because public utility tax rolls could be raised only by a two-thirds vote of the Legislature (Cal. Const., former art. XIII, § 14, subd. (f)) and the public utilities possessed sufficient political power to block such tax increases [citation]. In the face of this crisis, the Legislature drafted and the voters adopted an amendment to the Constitution known as the Riley-Stewart Plan, which completely revised this system of taxation.

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Bluebook (online)
Pacific Bell Telephone Co. v. County of Ventura, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pacific-bell-telephone-co-v-county-of-ventura-calctapp-2025.