City of San Jose v. Howard Jarvis Taxpayers Assn.
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The case involves the City of San José and the Howard Jarvis Taxpayers Association (HJTA). The city had a significant unfunded liability in its pension plans for city employees. To address this shortfall, the city council adopted a resolution authorizing the issuance and sale of bonds, provided they result in savings for the city. The HJTA argued that this action violated the constitutional debt limitation, which prohibits cities from incurring any indebtedness or liability exceeding the income and revenue provided for a given year without the assent of two-thirds of the voters.
The trial court upheld the city's actions, ruling that the bond issuance falls under the obligation imposed by law exception to the debt limitation. The HJTA appealed this decision, arguing that the city's actions violate the constitutional debt limitation and lack statutory authority.
The Court of Appeal of the State of California, Sixth Appellate District, affirmed the judgment, but for different reasons than the trial court. The appellate court concluded that the city has not incurred any indebtedness or liability exceeding its annual income and revenue because the city's actions do not trigger the constitutional debt limitation. The court also found that the city has the authority under state law to issue the bonds.
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