Sears, Roebuck & Co. v. County of Los Angeles

Opinion

FLEMING, J.

Defendants County of Los Angeles and City of Compton appeal a judgment in favor of plaintiff Sears, Roebuck & Company in an action to recover taxes paid under protest. The issue is whether certain goods imported by Sears and stored in its warehouses pending distribution to Sears’ retail outlets during fiscal years 1973, 1974, and 1975 are immune from ad valorem taxation.

This litigation tracks certain changes in the applicable statutory and case law, which we summarize as follows: The import-export clause of the United States Constitution prohibits the states from laying any…