Heckendorn v. City of San Marino

Opinion

REYNOSO, J.

What does the term “ad valorem tax” mean in article XIII A of the California Constitution? We conclude that an ad valorem tax, unlike the tax here involved, is any source of revenue derived from applying a property tax rate to the assessed value of property.

The City of San Marino (City) drafted an ordinance purporting to levy a special tax for police and fire services. The ordinance went into effect after approval by more than two-thirds of the City’s voters. Philip R. Heckendorn, a City property owner, filed a complaint for declaratory relief and injunction, alleging that…