California Supreme Court

Wilde v. City of Dunsmuir

August 3, 20209 Cal. 5th 1105

Summary

The court held that municipal water rates adopted by a general law city are tax measures exempt from the constitutional referendum power. The court concluded that the term "tax" in the referendum provision is not limited by the narrower definitions used for other constitutional revenue provisions, and that the exemption protects essential governmental operations from disruption. The court also held that the phrase "for usual current expenses" modifies appropriations, not tax levies, and therefore does not exclude water rates funding infrastructure improvements.