BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 261
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          Date of Hearing:   May 27, 2011

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                Felipe Fuentes, Chair

                   AB 261 (Dickinson) - As Amended:  May 11, 2011 

          Policy Committee:                              Revenue and 
          Taxation     Vote:                            8-0

          Urgency:     No                   State Mandated Local Program: 
          Yes    Reimbursable:              Yes

           SUMMARY  

          This bill clarifies that prescriptive easements run with the 
          tax-defaulted property sold in a tax sale and provides that a 
          proceeding based on alleged invalidity or irregularity of a sale 
          of tax-defaulted property may only be commenced by a recorded 
          interest holder or his/her successors, as specified.  
          Specifically, this bill:  

          1)Specifies that, in the case of a tax-defaulted property sale, 
            the title conveyed to the purchaser is not free from 
            prescriptive easements or easements of any kind, among other 
            liens and encumbrances.  

          2)Provides that a proceeding based on alleged invalidity or 
            irregularity of a tax lien sale may be commenced only by 
            recorded interest holders and their successors in interest in 
            the real property sold at the challenged tax sale.  

           FISCAL EFFECT  

          Negligible GF impact and potential savings to counties as a 
          result of.

           COMMENTS  

           1)Author's Statement  .  The author contends, AB 261 is a modest 
            measure to clarify the complex area of tax lien sales of real 
            property, ultimately protecting taxpayers.

           2)Argument in Support  .  The California Association of County 
            Treasurers and Tax Collectors, the bill's sponsor, argues that 








                                                                  AB 261
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            AB 261 is a simple, common sense measure that provides 
            protections for counties conducting tax lien sales by ensuring 
            that third parties cannot initiate or intervene in litigation 
            to invalidate tax sales without cause.

           3)Background.   Recently, the County of Sacramento was sued by a 
            person who did not have a recorded interest in the property 
            sold at a tax sale.  One of the issues in that case was 
            whether the alleged easement holder had the right to challenge 
            a tax sale of a property in which the easement holder had no 
            recorded interest, for example, a prescriptive easement.  
            According to the author, the court struggled with the issue 
            but reasoned that, since existing law is silent on the issue, 
            anyone, including the alleged easement holder, has standing to 
            sue the county and challenge a tax lien sale.  Counties are 
            concerned the court's decisions to allow unrelated third 
            parties to bring legal actions to undo transactions, will be 
            at great expense to the counties. 
           
          4)Prescriptive Easements  .  An easement is merely a right to use 
            the land of another, a restricted right to specific, limited, 
            definable use or activity upon another's property.  Easements 
            are usually obtained through a written agreement, but a 
            prescriptive easement is acquired through continuous use of 
            another person's property, without the owner's permission, for 
            a period of five years under California law.  Thus, a 
            prescriptive easement is an easement that has not been 
            recorded.  
           
          5)Proposed Solution  .  Effectively, this bill would overturn the 
            court's decision in the recent County of Sacramento case and 
            will therefore limit the plaintiff's standing to challenge the 
            tax lien sale and would limit the ability of unrelated third 
            parties to sue counties and challenge a tax lien sale.  
            Specifically, AB 261 provides that only recorded interest 
            holders and their successors in interest in the real property 
            sold at the challenged tax sale may institute a legal 
            proceeding and, thus, denies standing to challenge a tax lien 
            sale based on irregularities to holders of unrecorded 
            interests in the property, including prescriptive easements.  
            People with unrecorded prescriptive easements would still be 
            able to enforce their interests against the buyer, as long as 
            they could establish the existence of the easements.  
            Arguably, they would not be interested in blocking the tax 
            sale as long as other avenues of asserting their rights exist. 








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           6)There is no recorded opposition to this bill  .



           Analysis Prepared by  :    Roger Dunstan / APPR. / (916) 319-2081