English

This is an appeal from a judgment denying a petition for a writ of mandate.

Petitioners (appellants) are resident citizen-taxpayers who brought this class action on behalf of themselyes and all other taxpayers similarly situated. Respondents are the Assessors and Counties of Alameda, Contra Costa, Los Angeles, Marin, Orange, San Bernardino, San Diego, San Francisco, Santa Barbara, San Mateo and Santa Clara, and the State Board of Equalization. The Hospital Association of Northern California, the California Hospital Association, and the California Association of Homes for the Aging participate in the action as intervening parties.

The petition sought to compel respondents to identify, appraise and assess the tenancies or other possessory interests of certain employees and beneficiaries (i.e., hospital and college administrators, professors, doctors, nurses, aged persons) who occupy quarters or use property owned by tax-exempt colleges, universities, hospitals and other nonprofit organizations. It was stipulated by the parties that each category of the above institutions is properly exempt from property taxation either under California Constitution (Const.), article XIII,…