Citation Edit

Oates v. County of Sacramento, 78 Cal. App. 3d 745, 143 Cal. Rptr. 337 (1978) (full-text).

Factual Background Edit

Oates owned real property leased to the county superintendent of schools for administrative purposes. A portion of the space was used by the superintendent to store educational tapes and to house a print shop and computer data processing center. Some of the educational tapes and some of the computer time were rented out to private schools. Oates sued for the refund of taxes paid on building space leased to the superintendent, arguing that under the California Constitution,[1] the property was exempt from property taxation.

Trial Court Proceedings Edit

The trial court ruled against Oates on the ground that the property was not exclusively used for the purpose found in the exemption, but its use was only incidental to the public school system. The court of appeal reversed and remanded for apportionment proceedings, holding that the term "exclusively" includes incidental as well as primary uses; such incidental use, however, must be directly connected with, essential to, and in furtherance of the primary use. The court further held that the extent of the nonpublic use of the computer was de minimis because it serviced school districts in Northern California, the State Department of Education, and the Chancellor's Office of the Community Colleges and because private users paid for only 3% of the computer time.


  1. Cal. Const. art. XIII, § 3(d) provides, inter alia: "The following are exempt from property taxation: (d) Property . . . used exclusively for public schools.”

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