In Stribling's Nurseries, Inc. v. County of Merced (1965) 232 Cal.App.2d 759, the Court addressed the proper classification of nursery stock in relation to the growing crop exemption. The Court initially determined that the Cottle v. Spitzer (1884) definition is the correct meaning of "growing crop" as that term is used under former article XIII, section 1 of the California Constitution. ( Stribling's Nurseries, Inc., supra, at p. 762.) The Court then stated: "We find no case overruling either Cottle or Jackson & Perkins. Therefore the language 'growing crops' in article XIII, section 1, of the Constitution does not include growing nursery stock unless it meets the Cottle test of annual planting or sowing or an annual harvesting. In this case, plaintiff nursery has not contended that nursery stock meets this requirement." (Ibid.) Based upon the fact that nursery stock did not constitute a growing crop, this court invalidated a statute attempting to impermissibly exempt such plants from taxation. ( Id., at p. 763.)