Shapiro

I.

INTRODUCTION

In 1978, California voters enacted Proposition 13, which amended the California Constitution by adding article XIIIA (article XIII A). The amendment “ploc[ed] significant limits on the taxing power of local and state governments.” (State Building & Construction Trades Council of California v. City of Vista (2012) 54 Cal.4th 547, 562, fn. 3 [ 143 Cal.Rptr.3d 529 , 279 P.3d 1022].) As pertinent here, article XIII A, section 4 provides, “Cities, Counties and special districts, by a two-thirds vote of the qualified electors of such district, may impose special taxes on such district. . . .” (Italics added.)

In 1996, California voters enacted Proposition 218, which added article XIII C (article XIII C) and article XIII D (article XIII D) to the California Constitution in order to “close government-devised loopholes in Proposition 13.” (Apartment Assn. of Los Angeles County, Inc. v. City of Los Angeles (2001) 24 Cal.4th 830, 839 [ 102 Cal.Rptr.2d 719 , 14 P.3d 930 ] (Apartment Assn. of Los Angeles County, Inc.).) Article XIII C, section 2, subdivision (d) provides, “No local government may impose, extend, or increase any special tax unless and until that tax…