City of Rancho Cucamonga v. Mackzum

In City of Rancho Cucamonga v. Mackzum (1991) 228 Cal. App. 3d 929 [46 Cal. Rptr. 2d 448], the court recognized that "the purpose of Proposition 13 itself was to achieve statewide control over escalating local property tax rates." ( Id. at p. 945.) The court determined that Proposition 13 was a grant of authority to the Legislature to act in an area of statewide concern, and therefore, controlled over the home rule taxing power of charter cities. (228 Cal. App. 3d at p. 945.) The court concluded that although the home rule power was limited, it was not repealed. When considering the same objection in relation to the ERAF legislation that supports the claim in this appeal, the court in Sasaki, supra, 23 Cal. App. 4th 1442, found that shifting property tax revenues away from local governments did not result in impermissible infringement on the home rule powers. ( Id. at p. 1457.) Neither the record in this case nor the ERAF legislation suggests that the Legislature has infringed upon the County's discretionary affairs so as to interfere with the rights of local residents to home rule.