Brooktrails Township Com. Services Dept. v. Bd. Super. Mendocino Cty. CA1/2

Opinion

RICHMAN, J.

Proposition 218, adopted by the voters in 1996, added articles XIII C and XIII D to the California Constitution. 1 One of its most prominent features was to tighten the two-thirds voter approval requirement for “special” taxes and assessments imposed by Proposition 13. (Art. XIII A, § 4; Art. XIIIC, § 2, subd. (d); see art. XIII D, §§ 3, 4, subd. (g), 6, subd. (c).) 2 In Paland v. Brooktrails Township Community Services Dist. Bd. of Directors (2009) 179 Cal.App.4th 1358 [102 Cal.Rptr.3d 270] (Paland I), Division Five of this appellate district concluded that “a minimum…