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Sinclair Paint Co. v. State Bd. of Equalization
No. SO54115 (Cal. Sup. Ct. June 26, 1997) ; Clearinghouse Number: 50702
Description
California Childhood Lead Poisoning Prevention Act’s Imposition of Fees on Lead Paint Manufacturers Upheld
Abstract
The California Supreme Court has held that fees imposed under
California’s Childhood Lead Poisoning Prevention Act are not
"taxes" required to be enacted by a two-thirds majority
of the state legislature. The Act provides evaluation, screening,
and medically necessary follow-up services for children deemed
potential victims of lead poisoning. These programs are funded
entirely by fees assessed on manufacturers or others contributing
to environmental lead contamination. Arguing that the fees imposed
by the Act were actually taxes, plaintiff paint manufacturer
claimed that the Act was invalid on its face because it had not
been passed by a two-thirds majority vote of the state legislature.
The trial court found that the Act imposed an unconstitutional tax
and granted plaintiff’s motion for summary judgment. The
appellate court affirmed, and defendant state officials appealed.
Reversing, the supreme court held that the Act imposed bona fide
regulatory fees, not taxes, on plaintiffs. The court noted that the
legislature had imposed the fees to mitigate the actual or
anticipated adverse effects of the fee payers’ operations
and, under the Act, the amount of the fees must bear a reasonable
relationship to those adverse effects.
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