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Star-Kist Foods, Inc. v. Quinn, 54 Cal.2d 507, 354 P.2d 1, 6 Cal.Rptr. 545

Facts

Star-Kist Foods, Inc. leased land and improvements owned by the City of Los Angeles. The assessments on these leasehold interests were made without deducting the present worth of future rentals, which Star-Kist argued was required by Section 107.1 of the Revenue and Taxation Code. Star-Kist did not seek correction from the local Board of Equalization but instead pursued a writ of mandate to compel the assessor to cancel the assessments. The assessor contended that the statute was unconstitutional and that Star-Kist's failure to apply to the local board precluded judicial relief.

Star-Kist Foods, Inc. leased land and improvements owned by the City of Los Angeles. The assessments on these leasehold interests were made without deducting the present worth of future rentals, which Star-Kist argued was required by Section 107.1 of the Revenue and Taxation Code.

Issue

Whether the court should issue a writ of mandate to compel the assessor to cancel the tax assessments on Star-Kist's leasehold interests, given that the taxpayer had not exhausted administrative remedies.

Whether the court should issue a writ of mandate to compel the assessor to cancel the tax assessments on Star-Kist's leasehold interests, given that the taxpayer had not exhausted administrative remedies.

Rule

Mandamus will not issue when the petitioner has a plain, speedy, and adequate remedy in the ordinary course of law, such as paying taxes under protest and suing for recovery.

Mandamus will not issue when the petitioner has a plain, speedy, and adequate remedy in the ordinary course of law, such as paying taxes under protest and suing for recovery.

Analysis

The court analyzed the situation and determined that Star-Kist had an adequate remedy available by paying the taxes under protest and subsequently suing for recovery. The court noted that the necessity of recourse to the local board of equalization is determined by the nature of the issues in dispute, and since there was no dispute regarding the facts or the constitutionality of the statute, the local board's involvement was not required.

The court analyzed the situation and determined that Star-Kist had an adequate remedy available by paying the taxes under protest and subsequently suing for recovery.

Conclusion

The Supreme Court reversed the judgment of the Superior Court, concluding that Star-Kist had an adequate remedy and that mandamus would not issue.

The Supreme Court reversed the judgment of the Superior Court, concluding that Star-Kist had an adequate remedy and that mandamus would not issue.

Who won?

Los Angeles County Assessor prevailed in the case because the Supreme Court found that Star-Kist had an adequate legal remedy available, which negated the need for a writ of mandate.

Los Angeles County Assessor prevailed in the case because the Supreme Court found that Star-Kist had an adequate legal remedy available, which negated the need for a writ of mandate.

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