In White v. County of San Diego (1980) 26 Cal.3d 897, the county imposed special assessments on properties to pay part of the costs of widening and improving an adjacent street. (Id. at pp. 900-902.) The special assessments included the cost of acquiring rights-of-way. (Id. at p. 902.) Pursuant to the county's policy, each property was "assessed back" the amount paid for the right-of-way taken from that property, except those properties that had previously dedicated rights-of-way to the county were not so assessed. (Ibid.) Because of varying degrees of negotiation or litigation by property owners, there were disparities in the amount of compensation owners received for their rights-of-way and consequent disparities in the amounts assessed back to the properties of those owners for the right-of-way compensation. (Id. at p. 903.) White stated: "Property may be specially assessed only for improvements that provide it benefits beyond those received by the public. " (Id. at p. 904.) White concluded the record showed the project benefited all of the abutting properties by improving access, reducing congestion, improving traffic controls, improving drainage, and adding curbs, gutters, and sidewalks. (Ibid.) Although "an assessment must be generally proportional to benefits," the amount of each assessment need not be measured by the precise amount of benefit received by the property owner. (Id. at p. 905.) White stated: "In assessing the parcels from which the necessary land had not been dedicated, was it proper to measure the right-of-way assessment by the compensation paid for the strip taken? As indicated above, all the right-of-way strips, whether previously dedicated or acquired for the project, could reasonably be deemed to be of substantially the same worth in proportion to area and frontage and thus in proportion to the benefit to be received by the assessed parcel. The record does not show the extent to which the compensation paid may have departed from those proportionate values, but it was not unreasonable for the county to have assumed that such departures were due mostly or entirely to fortuitous variations in the processes of appraisal, negotiation, and litigation leading to the final determination of compensation. Assessing back the compensation avoided inequities based on such fortuities (e.g., making an owner who accepted the county's first offer contribute to an extraordinarily large judgment awarded a neighbor in a condemnation action). Speculation that the spreading of right-of-way costs on a basis other than assessment back might have resulted in correlating some individual assessments more closely with benefits does not invalidate the assessment methods used here, at least in the absence of mistake, fraud, or gross injustice. " (Id. at pp. 907-908.) Accordingly, the court affirmed the trial court's judgment denying the property owners injunctive relief regarding the special assessments. (Id. at pp. 900, 909.)