Campana

Background Legal Background “Proposition 218, approved by voters in 1996, is one of a series of voter initiatives restricting the ability of state and local governments to impose taxes and fees.” (Plantier v. Ramona Mun. Water Dist. (2019) 7 Cal.5th 372,

1 380.) Among other things, Proposition 218 added article XIII D to the California Constitution, which imposes “imposes distinct procedural and substantive limitations” on a local agency’s ability to extend, impose or increase “property-related fees” for services. (Id. at p. 381.) As relevant here, article XIII D, section 6, subdivision (b), places the following substantive limitations on property-related fees: “(1) revenues derived from the fee may not exceed the cost of providing the property-related service (id., subd. (b)(1)); (2) those revenues may not be used for any purpose other than the one for which the fee was imposed (id., § 6, subd. (b)(2)); [and] (3) the amount of the fee ‘shall not exceed the proportional cost of the service attributable to the parcel’ (id., § 6, subd. (b)(3) . . .).” (Plantier, supra, at p. 382, italics omitted.)1 In City of Palmdale v. Palmdale Water Dist. (2011) 198 Cal.App.4th 926, 936–938, the…