In Cottle v. Spitzer (1884) 65 Cal. 456, the California Supreme Court decided that fruit trees were not within the definition of growing crop contained in former article XIII, section 1, of the Constitution. ( Cottle, supra, at pp. 460, 464-465.) In so doing, the meaning of "growing crop" was clarified by the high court, which adopted the reasoning of Superior Court Judges Spencer and Belden. In Judge Spencer's opinion, ". . . it is at least doubtful if, under the common and restrictive acceptation of the term, anything more would be understood than products from annual plants, as cereals, maize, etc., . . ." ( Id., at pp. 457-458.) He also stated that ". . . in relation to the single term of 'growing crops,' my conclusion is that it is in effect a declaration that it is not sufficiently tangible to be treated as property; it is in a transitory state, starting with the embryo and ending with the matured product, at no two consecutive points of time in the same condition. To attempt to place upon it any money value, would be to indulge in the merest guess-work." ( Id., at p. 460.) Judge Belden's opinion contains the "growing crop" definition most frequently cited in subsequent precedents. He said that the term "'"includes only those crops which require an annual planting or sowing, or an annual harvesting."'" ( Id., at p. 463.) Judge Belden showed that this definition was the one prevailing at the time of the Constitution by penning that: "The members of this constitutional convention could but have been aware of the growing importance of the vine and fruit interest of the State. It was reported to them that fifty millions of capital was then employed in grape culture alone, and yet in all the debates upon this question, both upon the part of those who favored, and by those who opposed this exemption, constant reference is made to a crop to be sown and harvested within the same year, and not even a suggestion that trees or vines of perennial growth were referred to." ( Cottle v. Spitzer, supra, 65 Cal. at p. 463.) The Supreme Court also cited language from both judges which indicated that such tax exemptions should be construed narrowly. ( Cottle, supra, at pp. 459-460, 464-465.)