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Williams & Fickett v. County of Fresno

Supreme Court of California

June 5, 2017

Williams & Fickett, Plaintiff and Appellant,
County of Fresno, Defendant and Respondent.

         Court Superior County Ct.App. 5 F068652, No. 13CECG00461 Fresno Donald S. Black Judge

          Dowling Aaron Incorporated, Lynne Thaxter Brown and Ronald A. Henderson for Plaintiff and Appellant.

          Daniel C. Cederborg, County Counsel, Michal R. Linden and Peter Wall, Deputy County Counsel, for Defendant and Respondent.

          Mary C. Wickham, Interim County Counsel (Los Angeles) and Albert Ramseyer, Principal Deputy County Counsel, for California State Association of Counties as Amicus Curiae on behalf of Defendant and Respondent.

          Cantil-Sakauye, C. J.

         As a general rule, a party must exhaust available administrative remedies as a prerequisite to seeking relief in the courts. “In the property tax context, application of the exhaustion principle means that a taxpayer ordinarily may not file or pursue a court action for a tax refund without first applying to the local board of equalization for assessment reduction under [Revenue and Taxation Code] section 1603 and filing an administrative tax refund claim under section 5097.”[1] (Steinhart v. County of Los Angeles (2010) 47 Cal.4th 1298, 1308, italics omitted (Steinhart).) Our case law has recognized an exception to this general rubric where a tax assessment is “a nullity as a matter of law.” (Stenocord v. San Francisco (1970) 2 Cal.3d 984, 987 (Stenocord).) This case presents the question of whether the nullity exception applies, so that a timely assessment appeal is not required as a first step in the exhaustion process, when an assessment on nonexempt property is challenged on the ground that the taxpayer does not own the property involved.

         We conclude that in this scenario, the taxpayer must seek an assessment reduction through the assessment appeal process before the county board of equalization or a county assessment appeals board (county board), or obtain a stipulation under section 5142, subdivision (b) that such proceedings are unnecessary, in order to maintain a postpayment superior court action under section 5140 that seeks reduction of the tax. To the extent that our decision in Parr-Richmond Industrial Corp. v. Boyd (1954) 43 Cal.2d 157 (Parr-Richmond) provides otherwise, we conclude that it has been overtaken by intervening developments in the law, and overrule it. However, because plaintiff and others in its position could reasonably have relied on Parr-Richmond in opting not to pursue timely assessment appeal proceedings under section 1603, we give our ruling prospective effect only. We therefore affirm the judgment of the Court of Appeal.

         I. Facts and Procedural Background

         This is a tax refund action brought by plaintiff Williams & Fickett against defendant County of Fresno (County). Because this case is before us after the trial court sustained defendant's demurrer without leave to amend, we take the facts as stated in the operative complaint and its attachments to be true. (Steinhart, supra, 47 Cal.4th at p. 1304, fn. 1.) Plaintiff is a general partnership engaged in the business of farming in Fresno County. In 1997, the County's Office of the Assessor-Recorder conducted an audit of plaintiff. That audit eventually led to escape assessments[1] for the tax years 1994 through 1997 and assessments for the tax years 1996 through 2001, based on the assertion that plaintiff owned certain farming equipment that was not reported, or was incorrectly reported, on its personal property statements. In 1997, when the County first gave notice of the escape assessments, it informed plaintiff that if plaintiff wished to challenge the assessments, it had 60 days from the date of the notice to apply to the County's assessment appeals board for assessment reductions under section 1603. On the relevant lien dates, however, plaintiff did not own the farm equipment that was the subject of the assessments, and plaintiff neither paid the assessed taxes nor applied for assessment reductions under section 1603 within the 60-day period. The County then recorded certificates of delinquency related to the unpaid tax assessments, resulting in liens on plaintiff's real and personal property.

         In 2003, the County audited plaintiff's property tax declaration for the 2001 tax year. At that time, the County found an overassessment and gave plaintiff a refund for the 2001 tax year. The County declined, however, to grant refunds for previous tax years. In 2006, the County again audited plaintiff, and it again found an overassessment, giving plaintiff refunds for the tax years 2002 through 2005.

         Shortly after the 2006 audit, plaintiff hoped to refinance certain property, and it sought to clear the tax liens that encumbered that property. Plaintiff's attorney wrote to the County's auditor-controller, explaining: “From 1996 to the current date, Fresno County has erroneously assessed personal property taxes against my clients. For whatever reason, prior auditors felt that my clients and their secured creditors were lying when they presented evidence that a substantial portion of their personal property was seized as a result of their bankruptcy filings during 1997. This proof, rejected by the prior auditor, was accepted during the most recent [2006] audit.... [¶]... Since the property was returned to various secured creditors in 1997, the County lien, which appears to date back to 1996, must be significantly reduced[, ] as were the 2002-2005 taxes.” The County declined to reduce the liens.

         On June 13, 2007, plaintiff attempted to apply to the assessment appeals board for cancellation of the disputed assessments. These applications were submitted to the clerk of the board of supervisors using the County's printed form for applying for assessment reductions under section 1603.[2] That form includes a catchall option stating: “If you are uncertain of which item to check [regarding the basis of your application], please check ‘I. OTHER' and attach two copies of a brief explanation of your reason(s) for filing this application.” Plaintiff's attorney checked that catchall option on each of the applications and attached a statement saying, “This application is based upon Revenue and Taxation Code § 4986.”[3] The attachment further explained that as of the lien date, plaintiff was not the owner of most of the property being taxed. The County returned the applications unfiled, taking the view that they were untimely applications for assessment reductions under section 1603.

         About three years later, on November 24, 2010, plaintiff filed a complaint for declaratory relief against the County, asserting that the farm equipment in question had been “sold or returned to secured creditors, ” and therefore that the assessments related to the equipment should be cancelled. The trial court sustained a demurrer to the complaint, concluding that the complaint sought to enjoin the collection of property taxes, which is prohibited by both the state Constitution and state law (see Cal. Const., art. XIII, § 32; see also § 4807).

         In 2012, plaintiff paid the disputed taxes, including interest and penalties, and it then filed administrative refund claims under section 5097. The County denied those claims.

         Finally, in 2013, plaintiff initiated this action under section 5140, seeking to recover the taxes that it had paid. The superior court sustained the County's demurrer on the ground that plaintiff had failed to exhaust its administrative remedies by not filing timely applications for reduction of the challenged assessments under section 1603, subdivision (a). The Court of Appeal reversed, concluding that “where, as here, the taxpayer claims [an] assessment is void because the taxpayer does not own the [assessed] property, the taxpayer is not required to apply for an assessment reduction under section 1603, subdivision (a), to exhaust its administrative remedies.” We granted review.

         II. Discussion

         According to plaintiff, a taxpayer that asserts it does not own nonexempt assessed property need not first file and prosecute an assessment appeal under section 1603 et seq. in order to later pursue a refund action (see § 5140) after filing an administrative tax refund claim (see § 5097). As we will explain, against a backdrop of the general rule that requires the exhaustion of adequate administrative remedies, the statutory scheme for assessment appeals evinces the Legislature's intent that disputes such as the one at bar be presented, in the first instance, to a county board through the assessment appeal process. When a taxpayer seeks a reduction in an assessment on the local roll on the ground that it does not own the assessed property, the assessor and county board may agree with the taxpayer that the matter involves only a nonvaluation question; by statute, a stipulation to this effect will satisfy the exhaustion requirement of an assessment appeal. Otherwise, an assessment appeal must be pursued to resolution before the county board to preserve the taxpayer's right to later bring a refund action after payment of the tax. This design advances the salutary purposes served by the exhaustion requirement, while also allowing for expedited presentation of disputes to the courts in situations where, to all involved, a matter does not implicate the core of a county board's expertise.

         A. Exhaustion of Administrative Remedies

         The rule requiring exhaustion of administrative remedies is well settled. “In general, a party must exhaust administrative remedies before resorting to the courts. [Citations.] Under this rule, an administrative remedy is exhausted only upon ‘termination of all available, nonduplicative administrative review procedures.' [Citations.]” (Coachella Valley Mosquito & Vector Control Dist. v. California Public Employment Relations Bd. (2005) 35 Cal.4th 1072, 1080 (Coachella Valley); see also Abelleira v. District Court of Appeal (1941) 17 Cal.2d 280, 292-293.)

         The exhaustion rule “ ‘is not a matter of judicial discretion, but is a fundamental rule of procedure... binding upon all courts.' ” (Campbell v. Regents of the University of California (2005) 35 Cal.4th 311, 321 (Campbell).) We have explained that “[t]he exhaustion doctrine is principally grounded on concerns favoring administrative autonomy (i.e., courts should not interfere with an agency determination until the agency has reached a final decision) and judicial efficiency (i.e., overworked courts should decline to intervene in an administrative dispute unless absolutely necessary). [Citations].” (Farmers Ins. Exchange v. Superior Court (1992) 2 Cal.4th 377, 391; see also Rojo v. Kliger (1990) 52 Cal.3d 65, 83 [explaining that the exhaustion doctrine advances policy interests such as “easing the burden on the court system, maximizing the use of administrative agency expertise and capability to order and monitor corrective measures, and providing a more economical and less formal means of resolving [a] dispute”]; Yamaha Motor Corp. v. Superior Court (1986) 185 Cal.App.3d 1232, 1240 [observing that the exhaustion doctrine “ ‘facilitates the development of a complete record that draws on administrative expertise' ” and affords “a preliminary administrative sifting process [citation], unearthing the relevant evidence and providing a record which the court may review”].)

         As previously observed, “In the property tax context, application of the exhaustion principle means that a taxpayer ordinarily may not file or pursue a court action for a tax refund without first applying to the local board of equalization for assessment reduction under section 1603 and filing an administrative tax refund claim under section 5097.” (Steinhart, supra, 47 Cal.4th at p. 1308, italics omitted.) As plaintiff recognizes, it has long been held that taxpayers that claim that their property has been overvalued must exhaust the assessment appeal administrative remedy before resorting to the courts. (See, e.g., Dawson v. County of Los Angeles (1940) 15 Cal.2d 77, 81; Luce v. City of San Diego (1926) 198 Cal. 405, 406-407.) Plaintiff asserts, however, that this principle does not apply here, because its assertion of nonownership means that “there is no question of valuation involved which requires the local board[']s... expertise, and the board has no function to perform.”

         B. The Statutory Scheme for Assessment Appeals

         In evaluating this argument, we begin with the statutory scheme for assessment appeals. Pursuant to section 1603, “[a] reduction in an assessment on the local roll shall not be made unless the party affected or his or her agent makes and files with the county board a verified, written application showing the facts claimed to require the reduction and the applicant's opinion of the full value of the property.” (§ 1603, subd. (a).)[1] These appeals are then resolved through a process that can involve a public hearing (§§ 1605.4, 1605.6), exchanges of information (§ 1606), examinations under oath (§ 1607), and the collection and introduction of additional evidence in support or refutation of an appeal (§§ 1609, 1609.4, 1609.5, 1610.2). Ultimately, “the county board shall equalize the assessment of property on the local roll by determining the full value of an individual property, by assessing any taxable property that has escaped assessment, correcting the amount, number, quantity, or description of property on the local roll, canceling improper assessments, and by reducing or increasing an individual assessment....” (§ 1610.8; see also § 1605, subd. (e).)

         The statutory procedures associated with assessment appeals connote that the central responsibility of county boards is to decide questions of valuation. (E.g., § 1603, subd. (a).) But when a party seeks a reduction in an assessment on the local roll, pure questions of valuation are often inextricably connected to related issues of fact, such as whether a change in ownership has occurred, whether property has been properly classified, and whether a taxpayer in fact owns assessed property.[2]

         The statutory scheme recognizes the authority of the county boards to decide these issues. Particularly pertinent here are changes to and clarifications of the assessment appeal scheme that have occurred since 1978, the year in which the electorate passed Proposition 13. That measure “generally limits the maximum amount of any ad valorem tax on real property to 1 percent of its ‘full cash value.' (Cal. Const., art. XIII A, § 1, subd. (a).)” (Auerbach v. Assessment Appeals Bd. No. 1 (2006) 39 Cal.4th 153, 160.) Full cash value means “the county assessor's valuation of the property on the 1975-1976 tax bill ‘or, thereafter, the appraised value of real property when purchased, newly constructed, or a change in ownership has occurred after the 1975 assessment.' ([Cal. Const., art. XIII A], § 2, subd. (a)....)” (Ibid., italics omitted.)

         Proposition 13 thus connected property valuation with a nonvaluation question, i.e., whether a change in ownership has occurred. Initially, there was some doubt whether change in ownership issues lay within the purview of county boards, as part of the assessment appeal function. In 1986, the Legislature dispelled this uncertainty by adding section 1605.5, subdivision (a)(1), which provides that “[t]he county board shall hear applications for a reduction in an assessment in cases in which the issue is whether or not property has been subject to a change in ownership... or has been newly constructed....” (Added by Stats. 1986, ch. 1457, § 21, p. 5232.)[3] Steinhart, supra, 47 Cal.4th 1298, elaborated on the rationale behind this provision. There, we observed that “[i]n detailing the purpose of this section, the relevant legislative history explained: ‘The law is [currently] unclear if taxpayers can appeal the issue of whether or not there has been a change [in] ownership to either [a county board of equalization or an assessment appeals board]. [¶] This provision requires county boards of equalization and assessment appeals boards to hear change [in] ownership issues.' (Assem. Com. on Revenue & Taxation, Analysis of Assem. Bill No. 2890 (1985-1986 Reg. Sess.) as amended Mar. 19, 1986, p. 7.) Thus, section 1605.5, subdivision (a), expressly vests county boards with ‘jurisdiction... to adjudicate change [in] ownership disputes' between assessors and taxpayers and ‘contemplates' that such disputes will ‘be resolved by the local appeals board before resort is made to the courts.' [Citation.]” (Steinhart, at p. 1311, fn. and underscoring omitted.)

         Seven years later, the Legislature amended section 5142 to affirm that county boards have “jurisdiction over nonvaluation issues” (§ 5142, subd. (c)), while simultaneously adding a procedure that allows parties to avoid the assessment appeal process if they and “the assessor stipulate that an application involves only nonvaluation issues, ” a stipulation to this effect is filed with the county board, and the county board accepts this stipulation (id., subd. (b)). The county board's acceptance of the stipulation “shall be deemed compliance with the requirement that the person affected file and prosecute an application for reduction under Chapter 1 (commencing with Section 1601) of Part 3 in order to exhaust administrative remedies.” (Ibid.)

         Thus, although we have inferred an exhaustion requirement even within statutory schemes that “ ‘do not make exhaustion of the [administrative] remedy a condition of the right to resort to the courts' ” (Flores v. Los Angeles Turf Club, Inc. (1961) 55 Cal.2d 736, 747), here the relevant statutes provide affirmative indications of the Legislature's desire that claims such as plaintiff's be submitted to a local board through the assessment appeal process in the first instance as a prerequisite to later maintaining a refund action under section 5140. Although a taxpayer's contention that it does not own nonexempt property subject to an assessment arguably raises a nonvaluation issue, [4] the stipulation procedure bespeaks a legislative determination that the county board should, in the first instance, pass on this question, or decide that it need not do so. Indeed, the whole stipulation process - part of a “carefully crafted statutory scheme the Legislature has, within its constitutional authority, put in place” (Steinhart, supra, 47 Cal.4th at pp. 1312-1313, italics omitted) - would be meaningless, and section 5142, subdivision (b) would be surplusage, if an exhaustion requirement did not apply to nonvaluation issues.[5] If that were true, there would be no need for a taxpayer to seek a stipulation in order to obtain judicial review of a challenge to an assessment when the dispute did not involve a valuation issue.

         Application of the exhaustion rule to the circumstances present here also advances the purposes served by the exhaustion of administrative remedies requirement in general. A challenge brought on the ground of nonownership of assessed property will typically entail a question of fact, as to which administrative exhaustion through the assessment appeal process would facilitate the development of a record conducive to judicial review. The parties also might resolve their disagreement over ownership through the administrative process. Such an outcome could eliminate the need to pay the tax under dispute and bring a refund action, and thereby lessen the burden on the courts. Recognizing an assessment appeal as subsumed within the exhaustion requirement also supplies a timeline for the presentation and resolution of disputes such as this one. There is a time frame defined by statute for bringing and resolving an assessment appeal through administrative channels. (§§ 1603, subds. (b)-(d), 1604, 1605, subds. (b)-(e).) But no comparable deadline exists when the nullity exception applies. Where exhaustion is excused, therefore, the predictable result is stale claims like the one before the court in this case. The passage of time can make these claims difficult to adjudicate; it also hinders counties' ability to predict and budget for revenue.

         Plaintiff's efforts to reconcile its failure to exhaust administrative remedies with the statutory scheme, meanwhile, are unconvincing. Its arguments primarily concern the perceived inability of a party in its position to complete the application for reduction prescribed under section 1603. First, plaintiff asserts that a taxpayer that does not have a taxable connection to property[6] cannot fulfill section 1603, subdivision (a)'s requirement that an application seeking a reduction in an assessment include “the applicant's opinion of the full value of the property.” The inference plaintiff draws from this alleged roadblock is that a taxpayer that disclaims such a connection is neither required nor even permitted to file such an application. This reading of section 1603, subdivision (a) also informs plaintiff's construction of other aspects of the framework for assessment appeals. For example, plaintiff asserts that section 5142, subdivision (b)'s stipulation procedure applies only to those parties already required to file an application under section 1603, which (according to plaintiff), it did not have to do.

         We disagree with this construction of section 1603, subdivision (a). Although the language discussed above may reflect the reality that most assessment appeals involve what are by any measure valuation disputes, the requirement that the applicant venture an “opinion of the full value of the property” (§ 1603, subd. (a)) does not in practice interpose an insuperable obstacle to an administrative appeal of an assessment when a lack of ownership is asserted, and we doubt that the Legislature intended it as such. An applicant that disputes the ownership of assessed property nonetheless might have an informed opinion about the property's value. Also, where an applicant asserts that it does not own some or all of the personal property that has been grouped within a single assessment, the applicant could provide its estimate of the value of the specific pieces of property, if any, it concedes it owns (as plaintiff appears to have done in its 2007 applications). In a worst case scenario, an applicant that claims not to own property might opine that the true value is unknown, and explain why. A stipulation filed under section 5142, subdivision (b) must “[t]o the extent possible... indicate the parties' agreement as to the assessment amounts that would result under their respective positions on the issue or issues in dispute.” (Italics added.) Because “[t]he law never requires impossibilities” (Civ. Code, § 3531), a similar allowance presumably applies to applications under section 1603, subdivision (a).

         Plaintiff also argues that because it disclaims ownership of the property subject to assessment, it (and others in the same position) cannot execute the certification required under section 1603, subdivision (f). This certification provides, in relevant part, “I certify (or declare) under penalty of perjury under the laws of the State of California that... I am (1) the owner of the property or the person affected (i.e., a person having a direct economic interest in the payment of the taxes on that property - ‘The Applicant[.]' ” (See also Cal. Code Regs., tit. 18, § 301, subd. (g) [similarly defining a “ ‘person affected' or ‘party affected' ” as “any person or entity having a direct economic interest in the payment of property taxes on the property for the valuation date that is the subject of the proceedings...”].) Yet regardless of its contention that it does not own the property involved, plaintiff is a “person affected.” Having been identified by the County as the party responsible for the tax, it has a “direct economic interest in the payment of taxes on [the] property.” Plaintiff, and others in its position, therefore can execute this certification with a clear conscience.[7]

         C. The Nullity Exception and Parr-Richmond

         Given that requiring plaintiff to exhaust the administrative remedy provided by the assessment appeals process would comport with the statutory scheme and advance the general purposes served by the exhaustion rule, this would be an easy case but for our decision in Parr-Richmond, supra, 43 Cal.2d 157.

         “The doctrine requiring exhaustion of administrative remedies is subject to exceptions.” (Coachella Valley, supra, 35 Cal.4th at p. 1080.) “These exceptions are flexible.” (Campbell, supra, 35 Cal.4th at p. 322.) Departures from the general rule that demands exhaustion therefore are recognized in situations such as “when the administrative agency cannot provide an adequate remedy” and “when the subject of [a] controversy lies outside the agency's jurisdiction.” (Ibid.)

         This case does not implicate any of the generally applicable exceptions to the general exhaustion rule, however. The assessment appeal process does offer an adequate administrative remedy to a party that claims it was taxed for nonexempt property it did not own. And the statutory scheme's incorporation of provisions that expressly or implicitly recognize that county boards have authority to rule on nonvaluation questions in connection with an application seeking a reduction in assessment on the local roll forecloses any argument that these bodies lack jurisdiction over these issues.

         The nullity exception is instead specific to tax disputes. We have described this judicially designed rule as follows: “Ordinarily a taxpayer seeking relief from an erroneous assessment must exhaust available administrative remedies before resorting to the courts. [Citations.] An exception is made when the assessment is a nullity as a matter of law because, for example, the property is tax exempt, nonexistent or outside the jurisdiction [citations], and no factual questions exist regarding the valuation of the property which, upon review of the board of equalization, might be resolved in the taxpayer's favor, thereby making further litigation unnecessary [citations].” (Stenocord, supra, 2 Cal.3d at p. 987.)

         Parr-Richmond, supra, 43 Cal.2d 157, applied this exception to situations “where the taxpayer attacks the assessment as void because he does not own the property on which the tax demand was made, there is no question of valuation which must be presented first to the board of equalization for correction as a condition for judicial relief.” (Id., at p. 165.) As we explain, insofar as Parr-Richmond excused a failure to present a claim of nonownership of nonexempt property for review through the assessment appeal process, we believe it has been overtaken by developments in the statutory scheme for assessment appeals.

         Prior to Parr-Richmond, this court had been circumspect about recognizing any exception to the already longstanding rule requiring exhaustion of administrative remedies (see Fall v. City of Marysville (1861) 19 Cal. 391, 393) in situations where a taxpayer asserted nonownership of assessed property. Henne v. Los Angeles County (1900) 129 Cal. 297, 299, flatly rejected such an exception, endorsing instead the principle that “ ‘great mischiefs would follow if we were to hold that an excess of valuation would render an assessment illegal and void. And it is immaterial whether the excess is caused by including in the valuation property of which the person taxed is not the owner, or that for which he is not liable to be taxed. In both cases the remedy is the same.... His only remedy is application for abatement.' ” (Quoting Osborn v. Danvers (Mass. 1827) 6 Pick. 98, 100.)

         In 1911, however, Brenner v. Los Angeles (1911) 160 Cal. 72 (Brenner) partially repudiated this view. The court in Brenner announced that “we are of the opinion that, in so far as Henne v. County of Los Angeles places in the same category the mere over-valuation of property in an assessment thereof, and the inclusion in such an assessment of property not taxable at all, that case should be overruled.” (Id., at p. 76, italics added.) In Brenner, an assessment of real property did not deduct from the valuation the amount of a mortgage owned by the University of California, which was exempt from taxation. (Id., at pp. 73, 79.) The taxpayer “had no notice of the assessor's error until long after the possibility of seeking relief from the board of equalization had passed.” (Id., at p. 75.) Brenner held that under the circumstances presented, the taxpayer's failure to seek relief from the board of equalization did not bar the filing of a refund action. The court resolved, “it is time to renounce the doctrine that money paid under protest for taxes on property not liable to assessment cannot be recovered unless application is made for correction of the assessor's error before the period of equalization fixed by law has passed.” (Id., at p. 76, italics added.) In summing up the consequences of its affirmance of the judgment below, Brenner reiterated that “[b]y the judgment of the superior court herein the city of Los Angeles lost not a cent of taxes rightfully due upon plaintiff's property, while upon the opposite conclusion, plaintiff would be muleted, not for taxes due from some one else which through error or carelessness he had paid, but for a charge upon property free from any legitimate assessment by the city at all.” (Id., at p. 80, italics added.)

         Brenner, the principal wellspring of the nullity doctrine, is therefore distinguishable in two respects from this case: It involved a taxpayer who had no knowledge of the factual basis for his assessment dispute until after the window for challenging the assessment had closed, and the assessment was imposed on exempt property beyond the authority of the local board to tax, i.e., property that was “not taxable at all” and “not liable to assessment.” (Brenner, supra, 160 Cal. at p. 76.) Here, it is not asserted that the farm equipment that is the subject of the dispute is “not taxable at all.” Instead, the question is who should pay the tax. This difference matters because it affects the policy considerations that, in turn, inform construction of the exhaustion doctrine. Property that is exempt as a matter of law lies beyond the power of a local government to tax at any time. By contrast, had plaintiff timely presented and pursued an assessment appeal and established that it ...

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