Star-Kist Foods, Inc. v. County of Los Angeles

719 P.2d 987, 42 Cal. 3d 1, 227 Cal. Rptr. 391, 1986 Cal. LEXIS 186
CourtCalifornia Supreme Court
DecidedJune 30, 1986
DocketL.A. 31918
StatusPublished
Cited by59 cases

This text of 719 P.2d 987 (Star-Kist Foods, Inc. v. County of Los Angeles) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Star-Kist Foods, Inc. v. County of Los Angeles, 719 P.2d 987, 42 Cal. 3d 1, 227 Cal. Rptr. 391, 1986 Cal. LEXIS 186 (Cal. 1986).

Opinions

Opinion

REYNOSO, J.

We consider two questions: whether counties and municipalities may challenge the constitutionality of a statute exempting from ad valorem taxation business inventories of foreign origin or destination which are transshipped through the state; and if so, whether such exemption violates the commerce clause. We conclude that counties and municipalities may raise such a challenge, and that the statute in question offends the commerce clause.

The parties stipulated to the relevant facts. For tax year 1976-1977, defendants, Los Angeles County and the Cities of Los Angeles and Long Beach, assessed and levied ad valorem taxes on plaintiff Star-Kist Foods, Inc.’s1 inventory of canned tuna present in its California warehouses on March 1, 1976, the lien date.2 Star-Kist paid the tax, but sought a refund [5]*5of the $44,197 assessed on that portion of Star-Kist’s inventory that had been manufactured or produced outside the United States and brought into California for shipment to other states for sale in the ordinary course.3

Star-Kist based its refund claim on the exemption contained in newly enacted Revenue and Taxation Code4 section 225, which provided an exemption from taxation for “[p]ersonal property manufactured or produced, (1) outside this state and brought into this state for transshipment out of the United States, or (2) outside of the United States and brought into this state for transshipment out of this state, for sale in the ordinary course of trade or business. . . .”5

After exhausting its administrative remedies, Star-Kist brought suit in Los Angeles County Superior Court for refund of the contested taxes. Defendants asserted that the statutory exemption was invalid in that it violated the commerce clause of the federal Constitution (U.S. Const., art. I, § 8, cl. 3) by interfering with Congress’ plenary power over commerce, in that it discriminated against interstate commerce.

Relying on Zee Toys, Inc. v. County of Los Angeles (1978) 85 Cal.App.3d 763 [149 Cal.Rptr. 750], hearing denied, January 17,1979, affirmed without opinion by an equally divided court in Sears, Roebuck and Co. v. County of Los Angeles (1981) 449 U.S. 1119 [67 L.Ed.2d 106, 101 S.Ct. 933], in which the Court of Appeal held that section 225 violated the commerce clause and was void, the trial court denied plaintiff’s refund claim. This appeal followed.

I

Before reaching the merits of defendants’ charge that section 225 violates the commerce clause, we must determine whether defendants have “standing” to raise such a challenge to a state law. The term “standing” in this context refers not to traditional notions of a plaintiff’s entitlement to seek judicial resolution of a dispute,6 but to a narrower, more specific [6]*6inquiry focused upon the internal political organization of the state: whether counties and municipalities may invoke the federal Constitution to Challenge a state law which they are otherwise duty-bound to enforce.

Counties and cities must look to the state Constitution and the Legislature for their creation and delegated powers. (Cal. Const., art. XI, §§ 1, 2.) Counties are “merely . . . political subdivision[s] of state government, exercising only the powers of the state, granted by the state, created for the purpose of advancing ‘the policy of the state at large . . . (County of Marin v. Superior Court (1960) 53 Cal.2d 633, 638-639 [2 Cal.Rptr. 758, 349 P.2d 526].) Though municipalities may enjoy a greater degree of autonomy with regard to local affairs (Wilson v. Beville (1957) 47 Cal.2d 852, 858-859 [306 P.2d 789] [charter cities]), they too are subject to the sovereign’s right to extend, withdraw or modify the powers delegated. (Trenton v. New Jersey (1923) 262 U.S. 182, 187 [67 L.Ed. 937, 941, 43 S.Ct. 534, 29 A.L.R. 1471]. See People v. California Fish Co. (1913) 166 Cal. 576, 606 [138 P. 79].)7

This legislative control over cities and counties is reflected in the well-established rule that subordinate political entities, as “creatures” of the state, may not challenge state action as violating the entities’ rights under the due process or equal protection clauses of the Fourteenth Amendment or under the contract clause of the federal Constitution. “A municipal corporation, created by a state for the better ordering of government, has no privileges or immunities under the federal constitution which it may invoke in opposition to the will of its creator. [Citations.]” (Williams v. Mayor of Baltimore (1933) 289 U.S. 36, 40 [77 L.Ed. 1015, 1020, 53 S.Ct. 431]. Accord Newark v. New Jersey (1923) 262 U.S. 192, 196 [67 L.Ed. 943, 946, 43 S.Ct. 539] [equal protection clause]; Trenton, supra, 262 U.S. at pp. 185-187 [67 L.Ed. at pp. 940-941] [contract clause and Fourteenth Amendment]; Mallon v. City of Long Beach (1955) 44 Cal.2d 199, 209 [282 P.2d 481] [contract clause]; City of Los Angeles v. City of Artesia (1977) 73 Cal.App.3d 450, 457 [140 Cal.Rptr. 684] [contract clause and due process clause].) This rule’s application beyond Fourteenth Amendment and contract clause challenges remains unsettled.

[7]*7In City of South Lake Tahoe v. California Tahoe (9th Cir. 1980) 625 F.2d 231, certiorari denied, 449 U.S. 1039 [66 L.Ed.2d 502, 101 S.Ct. 619] (White, Marshall, JJ., dis.) the Ninth Circuit interpreted this “no standing” rule as absolutely barring political subdivisions from challenging state statutes on any federal constitutional ground. Regrettably, the South Lake Tahoe decision provides little guidance as to the court’s reasoning in choosing a per se rule.

The plaintiffs in South Lake Tahoe, the city and individual city council members, brought an action for declaratory and injunctive relief, attacking the validity of certain land use regulations and transportation plans adopted by a regional planning agency on four separate constitutional grounds: the plans and regulations violated the Fifth and Fourteenth Amendments in arbitrarily discriminating between similarly situated landowners, violated the right to travel, resulted in the taking of property without just compensation and conflicted with regulations of a congressionally approved bi-state planning agency in violation of the supremacy clause. The court rejected the city’s claim of standing to raise the constitutional claims based on the regulation’s injurious effects on its municipal finances. After noting that [political subdivisions may not challenge the validity of a state statute under the Fourteenth Amendment,’” and pointing out that it makes no difference whether the challenge is to the state or to a political subdivision thereof, the court simply concluded, “[t]hus, the city may not challenge [the] plans and ordinances on constitutional grounds.” (South Lake Tahoe, supra, 625 F.2d at p.

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Bluebook (online)
719 P.2d 987, 42 Cal. 3d 1, 227 Cal. Rptr. 391, 1986 Cal. LEXIS 186, Counsel Stack Legal Research, https://law.counselstack.com/opinion/star-kist-foods-inc-v-county-of-los-angeles-cal-1986.