Franchise Tax Board, Petitioner v. the Superior Court of the City and County of San Francisco, Respondent; Tom…

Summary

The court held that the California Constitution does not guarantee a jury trial in a statutory action seeking a refund of state income taxes. Although the action seeks monetary relief and resembles a common-law legal action, the statutory refund remedy is materially different from the historical action against individual tax collectors and is subject to legislative conditions. The court therefore reversed the Court of Appeal's contrary judgment.