Davis

This appeal challenges the constitutionality of Revenue and Taxation Code section 97.03, subdivision (c), which reallocates a percentage of property tax revenues from special districts to each county’s Educational Revenue Augmentation Fund. Eight fire protection districts, a municipal improvement water district which provides fire protection services based on a contract with a neighboring city, and nine individual taxpayers from Sacramento, San Diego, Solano, and Santa Cruz Counties, filed a petition for writ of mandate and complaint for declaratory relief against the State Controller, the State Director of Finance, and the county auditor-controllers for the four respective counties, challenging both the statute’s constitutionality and respondents’ computations pursuant to the statute. The trial court denied the petition and entered judgment for respondents on the complaint. We affirm.

Factual and Procedural Background

The Legislature enacted section 97.03 in 1992. Pursuant to subdivision (c) of this section, for fiscal year 1992-1993, each county was required to reduce the amount of property tax revenue allocated to each special district in the prior fiscal year by 35…