City & County of San Francisco v. Regents of the University of California

BANKE, J.,

Dissenting.—With the majority’s opinion, the law on whether a municipality can ask a state entity to collect a general local tax imposed not on the state entity, but on third parties doing business with the entity, is as follows: Irrigation districts providing electrical service (a proprietary activity because nonstate entities also produce electricity) can be required to collect a local utility users tax. (City of Modesto v. Modesto Irrigation Dist. (1973) 34 Cal.App.3d 504 [110 Cal.Rptr. 111] (City of Modesto)) Water districts providing water and sewer services (both governmental…