Coso Energy Developers v. County of Inyo

INTRODUCTION

Coso Energy Developers, Coso Finance Partners, and Coso Power Developers (the Coso entities) appeal from a judgment denying their claims for refunds of property taxes paid to the County of Inyo (Inyo). The Coso entities contend that Statutes 1891, chapter 181, section 1, page 262 (1891 Statute) precludes Inyo from taxing a portion of their geothermal energy operations located on land within the China Lake Naval Weapons Center (NWC). We disagree and affirm.

STATEMENT OF FACTS AND PROCEDURAL HISTORY

The essential facts were stipulated to by the parties or are undisputed. The Coso entities operate geothermal energy projects located within the NWC in Inyo County. The Coso entities operate their projects pursuant to certain contracts and leases with the United States Navy. Under these agreements, the Coso entities own the right to explore, develop, and take geothermal steam and related minerals from a portion of the land. They also own power plants, facilities, equipment, and personalty related to the projects.

The land on which the Coso entities operate their projects was ceded to the United States by Mexico pursuant to the Treaty of Guadalupe Hidalgo in…