Valley Baptist Church v. City of San RafaelAnnotate this Case
San Rafael voters approved by a two-thirds vote a Paramedic Services Special Tax, imposing an annual special tax up to a maximum of 14 cents per square foot on all nonresidential structures in the city to fund paramedic services. In 2015-2016, the city determined that the Assessor had been inadvertently omitted certain properties from the Paramedic Tax assessment. City officials rectified this oversight prospectively and sought to collect a portion of the Tax that had gone unpaid. One property owner that received notice of the levy was Valley Baptist, a nonprofit religious organization that operates a church on property within city boundaries. The city requested payment of $13,644.
Valley Baptist filed suit, challenging the constitutionality of the Tax as applied to a place of worship. Valley Baptist argued that it is exempted from payment of all property taxes under article XIII, section 3(f) of the California Constitution, including the Paramedic Tax. Reversing the trial court, the court of appeal held that the religious exemption does not extend to non-ad valorem special property taxes like the Paramedic Tax. The constitutional articles added by Propositions 13 and 218 do not evince an intent by the electorate to extend the scope of article XIII exemptions to special property taxes.