Pacific Bell Telephone Co. v. County of Napa

Filed 7/8/25

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION THREE

PACIFIC BELL TELEPHONE

COMPANY et al., Plaintiffs and Appellants, A170169

v. (Napa County COUNTY OF NAPA et al., Super. Ct. No. 23CV001211) Defendants and Respondents.

This is an action for refund of property taxes and declaratory relief by Pacific Bell Telephone Company, AT&T Mobility LLC, Sprint Spectrum, L.P., T-Mobile West LLC, and CenturyLink Communications LLC (“the Utilities”) against County of Napa (County) and the state Board of Equalization (Board) (“respondents”). The Utilities allege that from 2018 to 2023, the tax rates used to compute the debt-service component of their property taxes, as calculated pursuant to Revenue and Taxation Code section 100,1 were higher than the rates applied to other property in violation of section 19 of article XIII of the California Constitution (“article XIII, section 19”), which provides that public utility property “shall be subject to taxation to the same extent and in the same manner as other property.” In County of Santa Clara…