Western States Petroleum Association, Plaintiff and Respondent v. Board of Equalization, Defendant and Appellant

Summary

The court held that the Board's rule requiring petroleum refinery land, improvements, and fixtures generally to be valued as one appraisal unit was substantively consistent with the California Constitution and governing tax statutes. However, the Board failed to make a sufficiently reasoned and factually supported estimate of the rule's economic impact as required by the Administrative Procedure Act, so the rule was procedurally invalid and the judgment invalidating it was affirmed. Kennard, J., concurring in part and dissenting in part, agreed with the result but would have treated the rule as an interpretive regulation subject to less judicial deference.