Frederick

Plaintiffs Wayne L. Frederick and Darlene Frederick appeal from a judgment of the Sonoma County Superior Court denying them relief from an adverse decision of the county’s assessment appeals board (hereafter Board).

Plaintiffs Frederick were the owners of a Sonoma County home. Believing it to have been improperly assessed for real property taxation for the years 1977-1978 and 1978-1979, and fearful of such continued assessments, they commenced an action “for refund of taxes illegally assessed and collected . . . and for declaratory relief and a writ of mandate.”

The issue before the Board and later at the trial concerned the interpretation of certain language of the state’s Constitution, article XIII A, the so-called Proposition 13 adopted by the People June 6, 1978. Article XIII A, as here relevant, provides:

“Section 1. (a) The maximum amount of any ad valorem tax on real property shall not exceed one percent (1%) of the full cash value of such property. . . .

“Section 2. (a) The full cash value means the county assessor’s valuation of real property as shown on the 1975-76 tax bill under ‘full cash value’ or, thereafter, the appraised value of real property when . .…